By Moreta Bobokhidze, ModusA, 3 minutes reading.
On 11 December 2025, the European Court of Human Rights (ECHR) delivered a landmark judgment in Tsaava and Others v. Georgia, finding that the Georgian authorities violated three fundamental rights under the European Convention on Human Rights during the dispersal of the June 2019 protests in Tbilisi. The case involved 26 applicants—protesters and journalists who were injured when police used rubber bullets and other forceful measures outside the Parliament building during what became known as “Gavrilov’s Night.”
The Court ruled that Georgia breached Article 3 (prohibition of inhuman or degrading treatment), Article 10 (freedom of expression), and Article 11 (freedom of assembly and association). Under Article 3, the judges concluded that the excessive and indiscriminate use of kinetic impact projectiles against peaceful demonstrators amounted to inhuman and degrading treatment. Twenty‑four of the applicants were recognized as victims of such violations. The Court also criticized the Georgian authorities for failing to conduct effective investigations into police conduct, noting that the lack of accountability risked making such abuses systemic.
Under Article 10, the Court emphasized that journalists covering the protests were subjected to violence and intimidation, undermining their ability to report freely. This not only violated their individual rights but also had a chilling effect on media independence, striking at the heart of democratic society. Finally, under Article 11, the Court found that the authorities failed to distinguish between violent and non‑violent participants, dispersing the crowd indiscriminately and thereby infringing the right to peaceful assembly.
The judgment carries broader implications for Georgia and the region. It underscores the responsibility of governments to safeguard democratic freedoms even in moments of public unrest, and it highlights the importance of accountability mechanisms to prevent violations from becoming entrenched. For Georgia, the ruling is a reminder of the urgent need to align domestic policing practices with international human rights standards and to ensure that civic space remains protected.
In conclusion, the ECHR’s decision reaffirmed that state power must never override fundamental freedoms of dignity, expression, and peaceful assembly. By finding Georgia in breach of Articles 3, 10, and 11, the Court delivered justice to the applicants and set a precedent for protecting civic space in Europe’s emerging democracies. This ruling stands as a powerful reminder that the defense of human rights is inseparable from the defense of democracy itself.