
The Ministry of Justice of Georgia has issued a statement regarding the Grand Chamber judgment of the European Court of Human Rights (ECHR) in the case Tsaava and Others v. Georgia, concerning the protests on June 20–21, 2019.
According to the Ministry, the ruling reaffirms that a state has the legitimate right to use special means when law enforcement officers or state institutions are under attack. However, the Court found violations stemming from the failure of the then leadership of the Ministry of Internal Affairs to ensure that the use of force against demonstrators was proportionate.
“The Grand Chamber’s decision, delivered on December 11, 2025, addresses the rallies held on June 20–21, 2019, and the law enforcement response,” the Ministry stated. “The Court confirmed that the State may resort to special means in cases of assaults on police or attempts to storm state institutions. The judgment also notes that the escalation and storming of Parliament during the protests were instigated by opposition politicians. Force should have been applied specifically to demonstrators engaged in violent actions. The failure of the Ministry of Internal Affairs’ leadership to uphold this standard resulted in violations of Article 3 (prohibition of ill-treatment), Article 10 (freedom of expression), and Article 11 (freedom of assembly) of the European Convention on Human Rights.”
The Ministry emphasized that the Georgian government fully cooperated with the Court, providing all requested information and materials. Consequently, the Court dismissed applicants’ claims regarding a lack of cooperation and did not find it necessary to examine the complaint under Article 13.
Following the earlier ECHR Chamber judgment of May 7, 2024, Georgian authorities launched an investigation into the planning and execution of the police operation. On November 12, 2025, the Prosecutor’s Office initiated criminal proceedings against former Interior Minister Giorgi Gakharia, which remain ongoing.
In total, 26 applicants were involved in the case. The Strasbourg Court found that Article 3 had been violated in the cases of 24 applicants, Article 10 in 14 applicants, and Article 11 in 11 applicants.
For context, the Prosecutor’s Office has launched two criminal cases against former Prime Minister and Interior Minister Giorgi Gakharia, including one specifically related to the June 20–21, 2019 events. Gakharia has been ordered held in pre-trial detention in absentia.
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12/12/2025