In two communications to the Committee of Ministers in the context of the supervision of the execution of judgments of the European Court of Human Rights published today, the Commissioner addressed two groups of cases against Georgia. The Tsintsabadze v Georgia group of cases concerns various violations of the European Convention on Human Rights related to ill-treatment, mostly by law enforcement officers, and ineffective investigations into these violations. In this communication, the Commissioner underlines the need to ensure that law enforcement actions, particularly in the context of public assemblies, comply with the principles of legality, necessity, and proportionality. He also urges effective investigations into cases of ill-treatment and unlawful arrest and calls for the visible and individual identification of all law enforcement personnel.

In Makarashvili and Others v. Georgia, which is related to the arbitrary use of administrative detention during peaceful assemblies and insufficient judicial review, the Commissioner considers that the authorities should undertake a comprehensive reform of the Code of Administrative Offences. This should include effective consultations with experts from civil society, the Office of the Public Defender of Georgia and international bodies. He also recommends ensuring effective access to legal counsel, fair trial rights and timely, independent judicial oversight. Finally, he urges the revision of legislative changes adopted since November 2024 that disproportionately restrict the right to peaceful assembly.

These communications, submitted under Rule 9.4 of the Rules of the Committee of Ministers, are primarily based on the findings and recommendations of the Commissioner following his visit to Georgia from 21 to 23 January 2025.

• Read the Commissioner’s communication regarding Tsintsabadze v. Georgia and similar cases
• Read the Commissioner’s communication regarding Makarashvili and Others v. Georgia and 3 repetitive cases