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On December 11, 2025, the Grand Chamber of the European Court of Human Rights delivered a landmark judgment in Tsaava and Others v. Georgia . The case arose from the Georgian authorities’ forceful dispersal of major public protests outside the Georgian Parliament in Tbilisi on the night of June 20–21, 2019, also known as “Gavrilov’s night.” Thousands of people gathered to protest the authorities’ invitation to Sergei Gavrilov, an outspoken member of the Russian Duma, to sit in the chair reserved for the Speaker of the Georgian Parliament. The Grand Chamber found extensive violations of the European Convention on Human Rights stemming from the state’s violent dispersal of the protest and the excessive and indiscriminate use of “less-lethal” weapons, specifically kinetic impact projectiles and rubber bullets, against demonstrators and journalists. Beyond vindicating individual applicants, the Grand Chamber directed Georgia to take specific measures to conduct an effective investigation into the events and to put in place domestic regulations on crowd control and the limits of police force.
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Ramutè Remézaitè (2026) studied this question.
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