ECHR confirms Georgian authorities’ legitimate right to use special means when state bodies under attack and assault

The Georgian Ministry of Justice on Thursday announced that the Grand Chamber of the European Court of Human Rights (ECHR) has delivered its ruling in the case of Tsaava and Others v. Georgia.

The case concerns the protests held on June 20-21, 2019, and the use of special measures to disperse demonstrators.

According to the decision, the Grand Chamber reaffirmed the state’s legitimate right to use special measures in response to attacks and assaults on law enforcement officers and state institutions.

The ruling also notes that the escalation of the June 20 protest and the storming of the Parliament were encouraged by opposition politicians.

The Court emphasised that the force and special measures used by the state should have been directed only at demonstrators engaging in violent actions.

As the leadership of the Ministry of Internal Affairs at the time failed to ensure compliance with this standard and to use proportionate force against protesters, violations of Articles 3 (prohibition of inhuman or degrading treatment), 10 (freedom of expression), and 11 (freedom of assembly) of the European Convention on Human Rights were established.

The Grand Chamber also highlighted that the Georgian Government fully cooperated with the ECHR during the proceedings, providing all necessary information and materials. As a result, the applicants’ claims regarding violations of these aspects of the Convention were not upheld. The Court deemed it unnecessary to examine the case under Article 13 of the Convention.

The Government of Georgia had already addressed investigative shortcomings identified in the Chamber’s May 7, 2024 decision and launched an internal review of the planning and execution of the operation by the Ministry of Internal Affairs to ensure compliance with the standards set by the European Court.

Following this investigation, on November 12, 2025, the Georgian Prosecutor’s Office initiated criminal proceedings against former Minister of Internal Affairs Giorgi Gakharia. The investigation into the case is ongoing.