The Ministry of Justice of Georgia has released information regarding the Grand Chamber judgment of the European Court of Human Rights (ECHR) in the case concerning the June 20–21, 2019, protests.
According to the Ministry, today’s ruling once again confirms that a state has the legitimate right to use special means when law enforcement officers and state institutions come under attack. However, the Ministry notes that the violations identified by the Court stemmed from the failure of the then leadership of the Ministry of Internal Affairs to ensure that force used against demonstrators was proportionate.
“The ruling in the case Tsaava and Others v. Georgia, delivered on December 11, 2025, concerns the rallies held on June 20–21, 2019 and the use of special means to disperse the protest.
The Grand Chamber reaffirmed that the State may resort to special means in situations involving assault on law enforcement officers or storming of the state bodies. The judgment also notes that the escalation and storming of Parliament during the June 20 protests were instigated by opposition politicians. According to the ruling, the use of force should have been targeted specifically at demonstrators engaged in violent actions. Because the then leadership of the Ministry of Internal Affairs failed to ensure this standard, the Court found violations of Article 3 (ill-treatment), Article 10 (freedom of expression) and Article 11 (freedom of assembly) of the European Convention on Human Rights.
The Grand Chamber also highlighted that the Georgian government fully cooperated with the Court, providing all necessary information and materials. Therefore, the applicants’ claims regarding a lack of cooperation were dismissed. The Court did not consider it necessary to examine the complaint under Article 13.
Following the shortcomings identified by the ECHR Chamber judgment of May 7, 2024, the Georgian authorities launched an investigation into the planning and execution of the police operation. As a result, on November 12, 2025, the Prosecutor’s Office initiated criminal proceedings against former Minister of Internal Affairs Giorgi Gakharia. The investigation remains ongoing,” the Justice Ministry stated.
The Grand Chamber of the European Court of Human Rights has announced its decision in the case of Tsaava and Others v. Georgia, on December 11. A total of 26 applicants were involved in the case. The Strasbourg Court found that Article 3 of the European Convention on Human Rights — covering both inhuman or degrading treatment and the lack of an effective investigation — had been violated in respect of 24 applicants. The Court also ruled that Article 10 (freedom of expression) had been violated in the cases of 14 applicants, while Article 11 (freedom of assembly) had been violated in respect of 11 applicants.
For reference, the Georgian Prosecutor’s Office initiated two criminal cases against former Prime Minister and then Interior Minister Giorgi Gakharia. One of these cases concerns the events of June 20–21, 2019. Gakharia was ordered held in pre-trial detention in absentia.
