TSAAVA AND OTHERS v. GEORGIA - 13186/20 (Art 34 - No valid basis and reason allowing the Court to refrain from examining part of the case : Preliminary objection dismissed : Grand Chamber) [2025] ECHR 275 (11 December 2025)

TSAAVA AND OTHERS v. GEORGIA - 13186/20 (Art 34 - No valid basis and reason allowing the Court to refrain from examining part of the case : Preliminary objection dismissed : Grand Chamber) [2025] ECHR 275 (11 December 2025)

The Court found that the use of kinetic impact projectiles by police during the dispersal of the demonstration was neither strictly necessary nor proportionate, resulting in inhuman or degrading treatment in violation of Article 3 (substantive). The domestic legal framework regulating such use was deficient. The investigation into the applicants' injuries was ineffective and unduly prolonged, violating Article 3 (procedural). The use of force against journalists and demonstrators was not justified or necessary in a democratic society, violating Articles 10 and 11. The State failed to provide adequate protection for journalists and did not comply with its procedural obligations. The Court...

Citation
[2025] ECHR 275
Parties
Applicants: Tsaava and Others; Respondent: Georgia
Jurisdiction
European Union
Judgment Date
11 December 2025
Procedural Posture
Human Rights Application (echr) / Grand Chamber Judgment
Outcome
Violations found; just satisfaction awarded; orders for individual and general measures issued.
Legal Topics
Freedom of Expression, Freedom of Assembly, Prohibition of Inhuman or Degrading Treatment, Effective Investigation, Police Use of Force, Protection of Journalists
Human Rights Law Constitutional Law Criminal Law Freedom of Expression Freedom of Assembly Prohibition of Inhuman or Degrading Treatment Effective Investigation Police Use of Force +1 more

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Parties

Tsaava and Others

Applicants

Georgia

Respondent

Procedural Posture

Human Rights Application (echr) / Grand Chamber Judgment

Legal Issues

  1. 1 Whether the use of kinetic impact projectiles by police during the dispersal of a demonstration violated Article 3 (substantive and procedural) of the Convention
  2. 2 Whether the use of force against journalists and demonstrators violated Articles 10 and 11 of the Convention
  3. 3 Whether the investigation into police conduct was effective under Article 3 (procedural)

Ratio Decidendi

The Court found that the use of kinetic impact projectiles by police during the dispersal of the demonstration was neither strictly necessary nor proportionate, resulting in inhuman or degrading treatment in violation of Article 3 (substantive). The domestic legal framework regulating such use was deficient. The investigation into the applicants' injuries was ineffective and unduly prolonged, violating Article 3 (procedural). The use of force against journalists and demonstrators was not justified or necessary in a democratic society, violating Articles 10 and 11. The State failed to provide adequate protection for journalists and did not comply with its procedural obligations. The Court...

Court Disposition

Violations found; just satisfaction awarded; orders for individual and general measures issued.

Orders

  • Georgia must conduct an effective investigation into the applicants' injuries in compliance with Article 3 requirements, without delay and conclude it as quickly as possible.
  • Georgia must implement adequate safeguards regulating the deployment of kinetic impact projectiles to minimize risks of death and injury.