In
Georgia, across protest cycles from 2019 to 2026, a consistent pattern has
emerged: disproportionate and at times prohibited force against demonstrators; systematic
reclassification of allegations of torture and ill-treatment as lesser offences;
abolition of the only independent investigative body mandated to investigate
crimes committed by law enforcement officials; state honours awarded to
internationally sanctioned law enforcement officials; and sustained denial of
effective remedies to victims.
The
decisions, judgments and assessments of international human rights bodies
collectively establish the legal and factual context against which the
persistent challenges within Georgia's law enforcement system must be assessed.[1]
I.
A
Persistent Pattern: Police Violence Across Protest Cycles and beyond
(2019–2026)
2019: Gavrilov's Night and the Failure of
Accountability
The
December 2025 Grand Chamber judgment of the European Court of Human Rights,
concerning the dispersal of the 20–21 June 2019 protests known as
"Gavrilov's Night," confirmed the systemic ineffectiveness of
Georgian investigative authorities in responding to police violence.[2] Six years on, meaningful
accountability remains absent.
Despite
the severity of injuries sustained during and after June 2019, accountability
has been largely absent. Criminal proceedings against several lower-ranking
officers were later discontinued under amnesty measures, while no senior
officials responsible for planning, authorising, or supervising the operation
have been held accountable.
The then-Minister of Internal Affairs, Giorgi Gakharia, was subsequently
promoted to Prime Minister, and only in November 2025 was charged in absentia
in connection with the June 2019 dispersal — a development that has been
criticized by domestic and international observers as politically motivated.[3]
The
structural deficiencies identified by the Court persist across subsequent
protest cycles, raising serious concerns about Georgia's compliance with its
obligations under the European Convention on Human Rights and its commitments
as a member of the Council of Europe.
2023: Disproportionate Force Against Protesters
During
demonstrations against the proposed "foreign agents" law in March
2023,[4] riot police deployed tear
gas, water cannons, and stun grenades against protesters outside Parliament. At
least 169 people were arrested, with the majority alleging police beatings and
ill-treatment during or following their detention. Reportedly, one person
suffered permanent loss of sight after being struck by a rubber bullet.[5] To date, based on
available reports, the authorities have not acknowledged responsibility for
this injury or to investigate complaints of violence and ill-treatment arising
from these events.
2024: Documented Abuse and Alleged Prohibited Agents
Civil
society organisations, journalists, and international observers extensively
documented police violence against peaceful demonstrators and journalists
throughout 2024.[6]
Reports describe beatings during arrests, degrading treatment in detention,
sexualised and verbal abuse, unlawful searches, confiscation of personal
belongings, and the use of riot-control weapons including tear gas, pepper
spray, and water cannons—frequently corroborated by video evidence and
accompanied by serious injuries.[7]
On
1 December 2025, more than one year after the violent dispersal of protests in
November-December 2024, BBC Eye Investigations published a journalistic inquiry
alleging the use of chemically laced water cannons (containing Camite) against
protesters during the 2024 dispersals, supported by testimonies from injured
individuals.[8]
The State Security Service opened a criminal investigation but closed it within
five days, concluding that prohibited substance Camite had not been used.
Simultaneously, the Service opened criminal investigation into whether those
interviewed had “assisted a foreign organisation in hostile activities”.
In
line with no investigation into police violence, this response raised serious
concerns regarding the transparency, independence and impartiality of the
investigation and its compatibility with Georgia's obligations to conduct
effective investigations into allegations of torture and ill-treatment.[9]
Systemic Investigative Failures
Across
the 2019–2026 period, investigations into police violence have been
consistently and improperly downgraded. Rather than being pursued as cases of
torture or inhuman treatment under the relevant criminal provisions, complaints
are routinely reclassified as “abuse of authority,” a classification that
carries lesser penalties and risks undermining the level of accountability
required by the European Convention on Human Rights. Perpetrators are rarely
identified; victims are frequently denied proper legal status or effective
remedies; and systemic investigative inaction reinforces an entrenched culture
of impunity.
The
2024 annual report of the Ombudsperson of Georgia provides critical
quantitative evidence of systemic failure. Physical methods of violence
documented against individuals in police custody include punching, kicking,
tightening of handcuffs, arm-twisting, and forcible restraint. The proportion
of cases involving reported injuries has risen to 39.4% - the highest recorded
figure across the reporting period from 2020 to 2024, during which the rate
fluctuated between 26% and 34.4%. Far from improving, the data indicates a
deteriorating trajectory.[10]
During
the 2024–2025 protests in Georgia, the Public Defender documented severe human
rights violations. Of the 624 detainees visited by the Public Defender's
office, 360 individuals (57.7%) reported being subjected to inhuman or
degrading treatment or excessive use of force by law enforcement. Most notably
in April–May 2024 and November 2024–March 2025, reported abuse rates among
detainees surged to as high as 60%. The Public Defender also highlighted a
persistent failure to effectively investigate allegations of ill-treatment by
state agents, pointing to critical gaps in preventive safeguards, including
inadequate audio-video monitoring and the absence of clear officer
identification.[11]
Accountability Deficits in Law Enforcement Oversight
In
January 2025, eleven senior officials of the Ministry of Internal Affairs,
including individuals subject to international sanctions for human rights
violations, were awarded state honours for their “special contribution to
strengthening law and order,” at the request of Prime Minister Irakli
Kobakhidze and Parliament Speaker Shalva Papuashvili.[12] The Prime Minister
further announced that the State would fully compensate any officials suffering
financial losses as a result of sanctions.[13] These actions send a
strong signal of institutional endorsement of conduct that has been
internationally condemned, and are incompatible with Georgia's international obligations
to prevent and deter violations.
The
structural context has deteriorated further. In May 2025, the Georgian
Parliament abolished the Special Investigation Service—established in March
2022 following European Union recommendations specifically to investigate
crimes committed by law enforcement officers and public officials. With effect
from 1 July 2025, its mandate was transferred to the Tbilisi Prosecutor's
Office, an institution that is not independent of the executive and that is
part of the law enforcement system it would be required to scrutinise.[14]
According
to the 2025 annual report of the Prosecutor's Office of Georgia, authorities
launched investigations into 196 criminal cases of alleged ill-treatment
committed by public officials. Of these, 121 cases involved police officers, 7
occurred in penitentiary institutions, 5 involved court bailiffs, and 1 case
involved both, with victim status granted to 74 individuals. Notably,
prosecution was initiated in only 6 out of 196 cases — a figure that speaks to
the scale of alleged impunity of ill-treatment in Georgia.[15]
2025–2026: Continued Violence and Institutional
Deterioration
In
May and June 2026, video footage circulated on social media revealed further
instances of torture and inhuman treatment committed by police officers. One
incident, involving events from 2022, resulted in the arrest of the involved
individuals only in February 2026—four years after the fact on charges of abuse
of power involving violence.[16] A separate video showed
at least ten police officers beating a man over an alleged parking dispute in
Gori.[17] Following public outcry,
six officers were charged, but again, only with “abuse of power with the use of
violence”
On
7 May 2026, Georgia's Prosecutor General's Office arrested five current and
former law enforcement personnel for using violence against protester Zviad
Maisashvili, politician Levan Khabeishvili, and journalist Guram Rogava during
the 2024 Tbilisi protests. In this case, despite the grave nature of the
assault, documented by multiple sources, authorities charged the alleged
perpetrators with “abuse of power with the use of violence”. In addition, one
of them was charged with “unlawfully obstructing a journalist's professional
activities resulting in harm to health or other serious consequences.”[18]
These charges reflect a broader and deeper practice of downgrading conduct that may amount to torture or inhuman treatment to lesser administrative or criminal offences. As a result, those implicated in acts of violence, torture and ill-treatment evade accountability commensurate with the gravity of their conduct, while victims are deprived of effective remedies.
II.
International
Findings and Recommendations
The
lack of effective investigations into allegations of torture and ill-treatment
by the law enforcement authorities in Georgia have been consistently identified
and condemned across multiple international and domestic bodies.
The
European Court of Human Rights Grand Chamber (December 2025) confirmed the
systemic ineffectiveness of investigative authorities in responding to police
violence.
In regard of prohibition of torture and other
cruel, inhumane and degrading treatment or punishment, the Special Rapporteur
under the OSCE Moscow Mechanism report in respect of Georgia (March 2026) recommended
that
Ø the Georgian authorities
immediately end the disproportionate use of force, including torture and other
forms of ill-treatment;
Ø ensure that any use of force is
strictly proportionate,
Ø conduct prompt, independent and
impartial investigations into all allegations of abuse,
Ø guarantee humane treatment during
apprehension, transportation and detention,
Ø and adopt child-sensitive policing
practices to protect children during law enforcement operations.[19]
The
Council of Europe Monitoring Committee (May 2026) deplored the absence of
credible investigations into police brutality and expressed specific concern at
“reports that prohibited chemical agents have been used for the dispersal of
the protest in Tbilisi”.[20]
In
his June 2026 memorandum, Council of Europe Commissioner for Human Rights
Michael O’Flaherty criticized the substantial delays and limited progress in
investigations, called for thorough, independent, and transparent inquiries
into allegations of police abuse, including the use of chemically treated water
cannons, and urged Georgia to implement European Court of Human Rights
standards on effective investigations into ill-treatment by law enforcement.[21]
At
the domestic level, the Ombudsperson of Georgia's 2024-2025 Annual Reports
highlight complaints on abuse and ill-treatment in police custody — findings
that further corroborate the international consensus on the scale and
persistence of the problem.[22]
These
findings collectively point to a continuing structural problem requiring
systemic reform.
III.
Conclusions
and Recommendations
Georgia's
failure to fulfil its obligation to conduct effective investigations into
incidents of police violence, prosecute those responsible, and ensure effective
remedies for victims constitutes a continuing breach of both its obligations
under the Convention and those arising from the European Court of Human Rights
Grand Chamber judgment of December 2025. The abolition of the Special
Investigation Service, the normalisation of impunity for police violence, and
the systematic reclassification of serious acts of violence and ill-treatment
committed by law enforcement officials as lesser offences indicate a regression
in the effectiveness of the system rather than meaningful reform.
To address the
persistent pattern of police violence and impunity in Georgia, it is reccommended
to:
v Ensure
prompt, impartial, independent, and effective investigations
into all allegations of torture, ill-treatment, excessive use of force,
arbitrary detention, and other human rights violations committed by law
enforcement officials, in accordance with international human rights standards.
v Guarantee
the proper legal classification of acts of torture and ill-treatment,
ensuring that such conduct is investigated and prosecuted under the relevant
criminal offences rather than being downgraded to lesser offences.
v Establish
or restore a genuinely independent investigative mechanism
with the institutional, operational, and financial independence necessary to
investigate crimes committed by law enforcement officials, free from
prosecutorial or executive influence.
v Ensure
accountability at all levels of the chain of command,
including criminal, disciplinary, and administrative responsibility for
commanders and supervisors who order, condone, fail to prevent, or fail to
adequately respond to acts of alleged torture, ill-treatment, or unlawful use
of force.
v Provide
victims with effective remedies, including
access to justice, adequate compensation, rehabilitation, psychological
support, and guarantees of non-repetition, consistent with international
standards on the right to reparation.
v Strengthen
transparency and public oversight by publishing
comprehensive and disaggregated data on complaints against law enforcement
officials, investigations, prosecutions, disciplinary proceedings, convictions,
and reparations.
v Ensure
full cooperation with international human rights mechanisms,
including the implementation of recommendations and judgments issued by
international and regional human rights bodies, and facilitate independent
monitoring of law enforcement practices.
v Refrain
from rewarding or publicly endorsing officials credibly implicated in serious
human rights violations, including through the conferral of state
honours, promotions, financial benefits, or other forms of official
recognition, pending the completion of independent investigations.
v Review
and reform legislation, institutional policies, and operational practices
governing policing, use of force, arrest procedures, and detention to ensure
compliance with international human rights law and the absolute prohibition of
torture.
v Introduce
mandatory human rights training for all law
enforcement personnel, prosecutors, and judges, focusing on the prohibition of
torture, accountability for excessive use of force, effective investigation of
human rights violations, and the protection of fundamental freedoms during
assemblies and public demonstrations.
Meaningful
compliance with international human rights obligations requires structural
reforms that are measurable, transparent, independently monitored, and capable
of effectively preventing future violations while ending the longstanding cycle
of impunity for police misconduct.
[1] On 9–11 June 2026,
the Committee of Ministers of the Council of Europe called on Georgia to revise
its freedom of assembly legislation and ensure a fully enabling environment for
civil society, following supervision of the Makarashvili and Others v. Georgia
judgment, See Committee of Ministers,
Makarashvili and Others v Georgia (Application No 23158/20),
CM/Del/Dec(2026)1563/H46-14, Decisions of the Ministers' Deputies, 1563rd
meeting (DH), 9–11 June 2026, adopted 11 June 2026, available at https://hudoc.exec.coe.int/eng?i=CM/Del/Dec(2026)1563/H46-14E; and Council of
Europe Commissioner for Human Rights, Memorandum on Georgia: Council of Europe
Commissioner Calls for Accountability of Law Enforcement and Expresses Concerns
Regarding Mounting Restrictions on Democratic Freedoms, Strasbourg, 19 June 2026,
following the Commissioner’s visit to Georgia in April 2026, paras 9-10,
available at
https://rm.coe.int/memorandum-on-georgia-on-accountability-of-law-enforcement-and-freedom/48802c0ac8
[2] EHRAC, Gavrilov’s
Night – landmark judgment finds Georgian protestors and journalists suffered
ill treatment, 11 December 2025, available at https://ehrac.org.uk/en_gb/gavrilovs-night-european-court-judgment-georgia-protestors-journalists/
[3] Civil.ge,
“Ex-PM Gakharia Charged in Absentia Over ‘Gavrilov’s Night,’ Chorchana
Tensions”, 12 November 2025, available at https://civil.ge/archives/710537
[4] In March 2023, the
Georgian Dream political party initially passed the first reading of a bill
forcing organizations receiving over 20% of their funding from abroad to
register as “agents of foreign influence”. Following massive street protests in
Tbilisi and widespread international criticism, the ruling party officially
withdrew the package only re-introducing and adopting it in 2024.
[5] RFE/RL, Another
Eye Lost at a Protest, Demonstrations with Blank White Sheets, and a March
Against Hunger, 27 December 2023, available at https://www.radiotavisupleba.ge/a/%E1%83%A1%E1%83%90%E1%83%9E%E1%83%A0%E1%83%9D%E1%83%A2%E1%83%94%E1%83%A1%E1%83%A2%E1%83%9D-%E1%83%92%E1%83%90%E1%83%9B%E1%83%9D%E1%83%A1%E1%83%95%E1%83%9A%E1%83%94%E1%83%91%E1%83%98-2023-%E1%83%AC%E1%83%94%E1%83%9A%E1%83%A1/32749092.html [GEO]
[6] Rzebyk, Patrycja
(2026), OSCE Fact-Finding Mission on Georgia (2026) under Paragraph 12 of the
Moscow Mechanism: Report on Developments in Georgia in Respect of Human Rights
and Fundamental Freedoms since Spring 2024, Organization for Security and
Co-operation in Europe (OSCE), Office for Democratic Institutions and Human
Rights (ODIHR), 24 February 2026, paras. 126, 128, 130-131, 133, 135, 139-142,
144, 151, 293, 300, and 304.
[7] Public Defender of
Georgia, Annual Report on the Situation of Human Rights and Freedoms in Georgia
– 2024, pgs. 77-95, available at https://ombudsman.ge/res/docs/2025040121291438156.pdf [GEO]
[8] BBC, ‘WW1 toxic
compound sprayed on Georgian protesters, BBC evidence suggests’, 1 December
2025, available at https://www.bbc.com/news/articles/czrk7g50e1po
[9] Interpressnews,
‘State Security Service - Since the investigative actions on the fabricated
fact of the use of the so-called "camite" are over, the investigation
continues into a possible crime of assisting a foreign organization in hostile
activities’, 06 December 2025, available at https://www.interpressnews.ge/en/article/144446-state-security-service-since-the-investigative-actions-on-the-fabricated-fact-of-the-use-of-the-so-called-camite-are-over-the-investigation-continues-into-a-possible-crime-of-assisting-a-foreign-organization-in-hostile-activities/
[10] Public Defender of
Georgia, Annual Report on the Situation of Human Rights and Freedoms in Georgia
– 2024, pg. 45, available at https://ombudsman.ge/res/docs/2025040121291438156.pdf [GEO]
[11] Ibid,
pgs. 9, 78, 84, and 88
[12] Imedi TV, Mikheil
Kavelashvili awarded Vakhtang Gomelauri and other senior police officials the
Order of Honor, 30 January 2025, https://imedinews.ge/ge/politika/371839/mikheil-kavelashvilma-vakhtang-gomelauri-da-politsiis-skhva-khelmdzgvaneli-pirebi-girsebis-ordenit-daajildova [GEO]
[13] Civil.ge, GD
President Awards Sanctioned MIA Officials with Order of Honor, 30 January 2025,
available at https://civil.ge/archives/657740; Irakli Kobakhidze
Snubs US Sanctions by Decorating, Compensating Sanctioned MIA Officials (20
December 2025), available at https://civil.ge/archives/646989
[14] Democracy Research
Institute, DRI: Georgian Dream against the interests of the country and its
attempt to destroy state institutions, 21 May 2025, available at https://www.democracyresearch.org/eng/1643/
[15] Prosecution
Service of Georgia, 2025 Activity Report of the Prosecutor's Office of Georgia,
pgs. 136-137, available at https://pog.gov.ge/uploads_script/resources/tmp/php9IQU5i.pdf [GEO]
[16] Nodar Meladze,
video showing ill-treatment and torture by police officers, available at
https://www.facebook.com/nodar.meladze/videos/2289490045128077/
[17] Formula TV,
Footage from the Kombinati settlement showing police officers physically
assaulting a young man during his arrest, available at
https://www.facebook.com/TVFormula/videos/-%E1%83%99%E1%83%90%E1%83%93%E1%83%A0%E1%83%94%E1%83%91%E1%83%98-%E1%83%99%E1%83%9D%E1%83%9B%E1%83%91%E1%83%98%E1%83%9C%E1%83%90%E1%83%A2%E1%83%98%E1%83%A1-%E1%83%93%E1%83%90%E1%83%A1%E1%83%90%E1%83%AE%E1%83%9A%E1%83%94%E1%83%91%E1%83%98%E1%83%93%E1%83%90%E1%83%9C-%E1%83%A1%E1%83%90%E1%83%93%E1%83%90%E1%83%AA-%E1%83%90%E1%83%AE%E1%83%90%E1%83%9A%E1%83%92%E1%83%90%E1%83%96%E1%83%A0%E1%83%93%E1%83%90-%E1%83%9B%E1%83%90%E1%83%9B%E1%83%90%E1%83%99%E1%83%90%E1%83%AA%E1%83%98%E1%83%A1-%E1%83%93%E1%83%90%E1%83%99%E1%83%90%E1%83%95%E1%83%94%E1%83%91%E1%83%98%E1%83%A1%E1%83%90%E1%83%A1-%E1%83%9E%E1%83%9D%E1%83%9A%E1%83%98%E1%83%AA%E1%83%98%E1%83%94%E1%83%9A/2098334907435486/
[18] Amnesty
International, Georgia: Justice and accountability require more than criminal
charges against five police officers for assaulting protesters, 08 May 2026,
available at https://www.amnesty.org/en/latest/news/2026/05/georgia-justice-and-accountability-require-more-that-criminal-charges-against-five-police-officers-for-assaulting-protesters/
[19] OSCE
Office for Democratic Institutions and Human Rights (ODIHR), OSCE Fact-Finding
Mission on Georgia (2026) under Paragraph 12 of the Moscow Mechanism: Report on
Developments in Georgia in Respect of Human Rights and Fundamental Freedoms
since Spring 2024, by Professor Patrycja Grzebyk, Sole Rapporteur,
ODIHR.GAL/9/26/Corr.1 (12 March 2026), pg. 7, available at https://odihr.osce.org/sites/default/files/documents/official_documents/2026/03/odgal0009c1%20ODIHR%20NV%2082-2026%20report_Moscow%20Mechanism%20invoked%20in%20respect%20of%20Georgia_0.pdf;
[20] PACE, the
Monitoring Committee, Georgia: democratic backsliding and crackdown on
opposition and civil society continue, says PACE committee, 21 May 2026,
available at
https://pace.coe.int/en/news/10300/georgia-democratic-backsliding-and-crackdown-on-opposition-and-civil-society-continue-says-pace-committee
[21] Council of Europe
Commissioner for Human Rights, Memorandum on Georgia: Council of Europe
Commissioner Calls for Accountability of Law Enforcement and Expresses Concerns
Regarding Mounting Restrictions on Democratic Freedoms, Strasbourg, 19 June
2026, following the Commissioner’s visit to Georgia in April 2026, paras 6,
13-15, and 41, available at
https://rm.coe.int/memorandum-on-georgia-on-accountability-of-law-enforcement-and-freedom/48802c0ac8
[22] The Public
Defender's 2025 Annual Report similarly documented ongoing police violence
against detainees. Between 1 March 2025 and 20 February 2026, Public Defender
representatives visited 131 individuals detained in connection with protests,
of whom 35 (26.7%) reported ill-treatment and 17 showed visible injuries.
Described conduct included physical violence, degrading and insulting
treatment, verbal abuse, excessively tight handcuffing, and disproportionate
use of force. While the overall number of cases decreased compared to 2024 —
attributable to the reduced scale of protests rather than any improvement in
police conduct — the patterns of abuse remained consistent and unaddressed.
Public Defender of Georgia, Annual Report on the Situation of Human Rights and
Freedoms in Georgia – 2025, pgs. 77-80, available at https://ombudsman.ge/res/docs/2026040108450417707.pdf [GEO]
აფხაზეთის დე ფაქტო პარლამენტმა მიიღო საკანონმდებლო ინიციატივა, რომელიც მიზნად ისახავს ოკუპირებული აფხაზეთის პოლიტიკურ ცხოვრებასა და საარჩევნო პროცესებში უცხო ქვეყნის მოქალაქეებისა და მოქალაქეობის არმქონე პირთა უკანონო ჩარევის აღკვეთას.
DRI ეხმიანება 2026 წლის 27 ივლისს, MMA-ის მებრძოლ გიორგი ქართველიშვილის
მიერ გამართულ პრესკონფერენციაზე გაკეთებულ განცხადებას ე.წ. „სახალხო მოძრაობის“ დაფუძნების შესახებ.
მშვიდობიანი პროტესტის მონაწილეთა ძალის გამოყენებითა და ყოველგვარი განმარტების გარეშე დაკავება წარმოადგენს ავტორიტარული მმართველობისთვის დამახასიათებელი რეპრესიული პრაქტიკის გაგრძელებას.