In the complaint, reported by Expresso, Garcia Pereira asks Amadeu Guerra to proceed with the appropriate procedure for the dissolution of Chega.

He also requests the initiation of a criminal investigation against the party's president, André Ventura, and other leaders, for incitement to hatred, and the adoption of judicial and administrative measures for the urgent removal of posters with messages of "incitement to hatred and violence against groups of citizens".

In his argument, the lawyer recalls that the Constitution of the Portuguese Republic does not allow "racist organisations or those that espouse fascist ideology" and lists episodes of the conduct of Chega members that, he says, "represent raising to an (even) higher level a systematic behaviour of violation of those essential democratic principles".

The lawyer and university professor, among other examples, recalls the recent words of André Ventura, when he argued that Portugal needs "three Salazars," and the posters with messages referencing Bangladesh and the gyspsy community.

Garcia Pereira also cites the Chega party leader's social media posts against Roma people, when he refers to this community as "people who 'think they have rights and privileges' and who do not obey the law."

The author of the complaint also warns of a "trivialization of the most boorish insults and hate speech" against "political opponents and certain communities," recalling when the parliamentary leader of Chega, Pedro Pinto, argued, regarding the death of Odair Moniz, that "if the police shot to kill, the country would be in order."

António Garcia Pereira considers it clear that Ventura, as well as Rita Matias, Pedro Pinto, and Pedro Frazão, have “defamed groups of people because of their race, colour, ethnic or geographic origin, and religion, inciting and encouraging discrimination, hatred, and even violence against such groups.”

“Furthermore, there have already been several cases of completed and barbaric attacks against these citizens, occurring in the Algarve, Porto, and Greater Lisbon, causing everyone strong fear and constraint on their freedom of action (specifically, going out on the street and going to a café, to their children's school, or to the supermarket),” the complaint reads.

According to Garcia Pereira, no conception of freedom of expression “can justify this type of conduct,” and these behaviours are examples of “very serious and legally inadmissible violations of both fundamental principles of the democratic rule of law and the fundamental rights, freedoms, and guarantees of the citizens involved.”

The university professor considers that the Public Prosecutor's Office “has the legitimacy and obligation to initiate criminal proceedings to investigate and ascertain the facts,” recalling that it is up to this body “to exercise criminal action guided by the principle of legality and to defend democratic legality.”

“Which have thus been seriously, deliberately, overtly, and repeatedly violated by the conduct of the Chega party and its aforementioned President and top leader, André Ventura,” concludes the lawyer.