The European Court of Human Rights (ECtHR) found that Georgia violated the freedom of expression of Zurab Karchava, who was detained in 2022 after being prevented from setting up a protest tent in Batumi.
In a June 23 judgment in Karchava v. Georgia, the Court unanimously held that Georgia had violated Article 10 (freedom of expression) of the European Convention on Human Rights, read in the light of Article 11 (freedom of assembly and association), and ordered the state to pay EUR 1,000 in compensation.
The case concerns a solo protest planned by Karchava at the end of 2022 to denounce the lack of free lunches in public schools in Georgia during the school year. He intended to set up a tent behind a statue of Memed Abashidze in a public square near the Constitutional Court of Georgia and the seat of local government, and to go on a hunger strike.
On the day the protest was due to begin, police officers tried to persuade him to change his plans as the area had been designated for New Year’s Eve celebrations, which included the potential use of pyrotechnics. They encouraged him to relocate to a different location. Around lunchtime, Karchava was arrested for “disobeying lawful police orders,” an administrative offence. He was later found guilty and given a verbal reprimand.
Karchava, who was represented before the Strasbourg Court by the Georgian Young Lawyers’ Association, complained that the interruption of his solo demonstration and his subsequent conviction for an administrative offence amounted to a violation of his rights to freedom of expression and peaceful assembly under Articles 10 and 11 of the European Convention on Human Rights.
Since 2022, Georgian Dream has tightened anti-protest legislation several times, as protesters in recent months have repeatedly been prevented by police from erecting tents or have had their tents removed. The October 2025 legislative changes stipulate that violations of protest rules – such as covering one’s face during demonstrations, carrying pyrotechnics, “artificially” blocking roads, or erecting “temporary structures” – result in immediate administrative detention of up to 15 days.
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