Judge Manuchar Tsatsua of the Tbilisi City Court found civil activist and protest participant Natashi Lazishvili liable for an administrative offence for standing on a sidewalk and imposed a verbal warning as a sanction. The Ministry of Internal Affairs alleged that on 18 December 2025, while standing on the sidewalk near the Parliament building, she deliberately obstructed the movement of citizens.
Natashi Lazishvili is the ninth individual to have been found liable for standing on a sidewalk in connection with protest activities. Of the nine cases to date, five individuals were sentenced to administrative detention, while four individuals including three women and Rezi Dumbadze, the first person found liable for standing on a sidewalk were issued verbal warnings.
On 12 December 2025, the “Georgian Dream” party adopted another repressive legislative amendment restricting the right to freedom of assembly. The amendments were adopted following accelerated parliamentary consideration over a three-day period. As a result of these amendments, protest activity on sidewalks was, in effect, also prohibited. For a first violation, the legislation provides for administrative detention for a period of up to 15 days (up to 20 days in the case of an organizer), while a repeated violation may result in the imposition of criminal liability. According to the assessment of Transparency International Georgia, “the detention of an individual for standing on a sidewalk, even under administrative procedure, let alone the imposition of criminal punishment cannot withstand any criticism when assessed against the standards of freedom of assembly guaranteed by the Constitution of Georgia and by international human rights instruments.”
On 23 January 2026, judges of the Tbilisi City Court found seven citizens liable for administrative offences in connection with standing on a sidewalk. Of these, five individuals (men) were sentenced to administrative detention, while two individuals (women) were issued verbal warnings, as follows:
- Sandro Megrelishvili – four days of administrative detention (Judge Davit Makaradze);
- Dimitri Jamburia – four days of administrative detention (Judge Davit Makaradze);
- Luka Nagliashvili – five days of administrative detention (Judge Davit Makaradze);
- Mikheil Zakareishvili – five days of administrative detention (Judge Zviad Tsekvava);
- Nukri Kakulia – four days of administrative detention (Judge Manuchar Tsatsua);
- Ani Akhmeteli – verbal warning (Judge Zviad Tsekvava);
- Natia Chavchanidze – verbal warning (Judge Manuchar Tsatsua).
The Ministry of Internal Affairs alleged that, by standing on the sidewalk, the individuals obstructed the movement of other citizens. This marked the first instance in which courts imposed administrative detention in proceedings related to the so-called “sidewalk cases.”
Another repressive legislative amendment restricting the exercise of the right to freedom of assembly was adopted by the “Georgian Dream” party on 12 December 2025. The amendments were adopted following accelerated parliamentary consideration over a three-day period. As a result of these amendments, protest activity on sidewalks was effectively prohibited. Under the amended legal framework, a first violation is punishable by administrative detention for a term of up to 15 days (up to 20 days in the case of an organizer), while a repeated violation may give rise to criminal liability.
The first activist to be subjected to court proceedings following the adoption of the stricter legislation was Ani Akhmeteli, who was served with notice on 23 December. The first judicial decision in sidewalk-related cases was delivered on 22 January, when Judge Tornike Kapanadze found civil activist Rezi Dumbadze liable for an administrative offence and issued a verbal warning. In the assessment of Transparency International Georgia, “the detention of an individual for standing on a sidewalk, even under administrative procedure, let alone the imposition of criminal punishment cannot withstand legal scrutiny when assessed against the standards of freedom of assembly guaranteed by the Constitution of Georgia and by international human rights instruments.”
On 22 January 2026, a precedent was established at the Tbilisi City Court, where the first ruling was delivered in the so-called “sidewalk case.” Judge Tornike Kapanadze found Rezi Dumbadze, a participant in pro-European demonstrations, liable for an administrative offence for standing on a sidewalk adjacent to the Parliament building and thereby “obstructing the movement of the public,” and issued a verbal warning as a sanction.
The Ministry of Internal Affairs alleged that Rezi Dumbadze committed the administrative offence on 17 December 2025. On 14 January, the protest participant was notified by the Tbilisi City Court that he was required to appear in connection with the alleged “blocking” of the sidewalk.
On 12 December 2025, the “Georgian Dream” party adopted another repressive legislative amendment restricting the right to freedom of assembly. The amendments were adopted following accelerated parliamentary consideration over a three-day period. As a result of these amendments, protest activity on sidewalks was, in effect, also prohibited. For a first violation, the legislation provides for administrative detention for a period of up to 15 days (up to 20 days in the case of an organizer), while a repeated violation may result in the imposition of criminal liability. According to the assessment of Transparency International Georgia, “the detention of an individual for standing on a sidewalk, even under administrative procedure, let alone the imposition of criminal punishment cannot withstand any criticism when assessed against the standards of freedom of assembly guaranteed by the Constitution of Georgia and by international human rights instruments.”
Rezi Dumbadze is the first civil activist to have been found liable under the so-called “sidewalk” cases.
The Ministry of Internal Affairs of Georgia has initiated a criminal investigation against civic activist Davit Gagrel in connection with standing on a sidewalk. As reported by the activist on social media, the court informed him that the administrative proceedings instituted against him had been terminated and that the case materials were remitted to the Ministry of Internal Affairs due to the presence of indicia of a criminal offense.
According to Davit Gagrel, the court indicated that the alleged act – obstructing pedestrians’ movement on a sidewalk on 18 December 2025 could not be assessed solely within the framework of administrative liability, as he had previously served detention under the same provision. On this basis, the administrative proceedings were discontinued and the case was referred to law enforcement authorities for criminal legal qualification.
The Ministry of Internal Affairs alleges that Davit Gagrel obstructed citizens’ movement in connection with a protest expressed on a sidewalk. On this basis, administrative proceedings have been instituted against protest participants since Georgian Dream adopted a further repressive legislative amendment restricting freedom of assembly on 12 December 2025, which in fact prohibited protests on sidewalks. Under the amended legal framework, a first violation is punishable by administrative detention of up to 15 days (up to 20 days for organizers), while a repeated violation may entail the imposition of criminal liability.
On the same legal grounds, the court has, to date, remitted the cases of five civic activists to the Ministry of Internal Affairs for further criminal-law assessment: Vazha Gaprindashvili, Giorgi Tsulaia, Ana Bdeiani, and father and son Kakha and Konstantine Mikaia. In total, six activists currently face the risk of criminal prosecution in connection with protests conducted on sidewalks.
On 16 January 2026, translator and civic activist Nino Bardzimashvili was detained in connection with an earlier road-blocking case. As established, at the end of December 2025, the court imposed a sentence of five days of administrative detention on her on the grounds of allegedly blocking a roadway during protests on Rustaveli Avenue in October.
The reasons why the activist was detained three weeks later for the execution of the custodial sanction remain unknown. She was detained near her residence and transferred to the Rustavi temporary detention isolator.
The Ministry of Internal Affairs has initiated criminal prosecution against civic activist Kakha Mikaia, a former member of the Political Council of Georgian Dream, and his son, Konstantine Mikaia, in connection with standing on a sidewalk. In an interview with TV Pirveli, Kakha Mikaia stated: “I received a decision stating that, following amendments to certain provisions of the Administrative Offences Code, the case has been transferred to criminal proceedings. This was expected from the current authorities.”
Father and son Kakha and Konstantine Mikaia are active participants in the protests on Rustaveli Avenue. Both had previously been subjected to administrative detention on the grounds of allegedly blocking a roadway. On 21 October 2025, Judge Nino Enukidze sentenced Kakha Mikaia, who had been detained during a protest on allegations of unlawfully blocking a roadway, to 14 days of administrative detention. On the same day, Konstantine Mikaia was also sentenced to 14 days of administrative detention. Prior to that, on 17 September 2025, Konstantine Mikaia had been detained for 10 days for non-payment of a fine.
The Ministry of Internal Affairs has been accusing individuals of obstructing citizens’ movement for protests expressed on sidewalks since Georgian Dream adopted another repressive legislative amendment restricting freedom of assembly on 12 December 2025, which in fact banned protests on sidewalks. Under the amended legal framework, a first violation is punishable by administrative detention for up to 15 days (up to 20 days for organizers), while a repeated violation may give rise to criminal liability.
On the same grounds, the court has, to date, referred the cases of three civic activists to the Ministry of Internal Affairs for further action: Vazha Gaprindashvili, Giorgi Tsulaia, and Ana Bdeiani.
Tbilisi City Court Judge Tornike Kapanadze terminated the administrative proceedings instituted against civic activist Ana Bdeiani and referred the case materials to the Ministry of Internal Affairs for further action. According to lawyer Marika Arevadze, the judge noted in the reasoned decision that the case may contain elements of a criminal offense.
The Ministry of Internal Affairs alleges that Ana Bdeiani, a mother of three, artificially obstructed a sidewalk. The administrative offense report was issued pursuant to Article 174¹, Part 10 of the Administrative Offences Code of Georgia. Ana Bdeiani had previously been subjected to administrative liability on 4 November 2025 on the grounds of the alleged artificial obstruction of a roadway.
Since Georgian Dream adopted another repressive legislative amendment restricting freedom of assembly on 12 December 2025, the Ministry of Internal Affairs has been initiating proceedings against civic activists for obstructing citizens’ movement in connection with protests expressed on sidewalks, which the amended legislation in fact banned. Under the amended legal framework, a first violation is punishable by administrative detention for a term of up to 15 days (up to 20 days for organizers), while a repeated violation may give rise to criminal liability.
On the same grounds, the court has, to date, referred for further action to the Ministry of Internal Affairs the cases of two civic activists – Vazha Gaprindashvili and Giorgi Tsulaia.
The Zugdidi District Court imposed an administrative fine of GEL 1,750 on Zugdidi-based civic activist and street artist Rostom Zarandia for creating the “Megobari Act” geoglyph, following an administrative complaint lodged by the Environmental Supervision Service of the Ministry of Agriculture and Environmental Protection.
The “Megobari Act” geoglyph is a 380-meter-long inscription created on agricultural land in western Georgia, near the coastal town of Anaklia. According to the activist’s explanation, the geoglyph was intended to draw the attention of the local and international public to the significance for Georgia of the “Megobari Act,” which has been initiated in the Senate. In connection with the same geoglyph, Rostom Zarandia had previously been subjected to an administrative fine of GEL 2,000 imposed by the Zugdidi City Hall.
Tbilisi City Court Judge Davit Makaradze remitted to the Ministry of Internal Affairs the case of civic activist and United National Movement member Giorgi Tsulaia, who had been accused of obstructing movement due to protesting on a sidewalk. The judge identified indicia of a criminal offense in Giorgi Tsulaia’s case, as the activist had previously been subjected to detention for blocking a roadway (on 22 October 2025, he was sentenced to eight days of detention).
The Ministry of Internal Affairs initiated new proceedings against Giorgi Tsulaia on 17 December 2025 in connection with his participation in a protest held on that date. On the same day, the Ministry initiated proceedings against more than 20 individuals, including doctor Vazha Gaprindashvili, whose case was likewise remitted to the Ministry of Internal Affairs.
Since Georgian Dream adopted another repressive legislative amendment restricting freedom of assembly on 12 December 2025, the Ministry of Internal Affairs has been initiating proceedings against protest participants with “obstructing citizens’ movement” for protests carried out on sidewalks, which the amended legislation in fact banned. Under the amended legal framework, a first offense is punishable by administrative detention of up to 15 days (up to 20 days for organizers), while a repeated offense may entail criminal liability.
Civic activist and doctor Vazha Gaprindashvili is facing the threat of criminal prosecution for standing on a sidewalk. The Ministry of Internal Affairs accuses him of “obstructing citizens’ movement” in connection with the protest held on 22 December 2025.
On 8 January, an administrative hearing was held in this case, after which Judge Tornike Kapanadze referred the case to the Ministry of Internal Affairs, citing the presence of elements of a criminal offense. Vazha Gaprindashvili has previously been identified as an administrative offender on the grounds of allegedly “blocking a roadway.”The Ministry of Internal Affairs has been bringing charges of “obstructing citizens’ movement” against protest participants for expressions of protest carried out on sidewalks since Georgian Dream adopted another repressive legislative amendment restricting freedom of assembly on 12 December 2025, which effectively banned protests even on sidewalks. Under the legislation, a first offense is punishable by administrative detention of up to 15 days (up to 20 days for organizers), while a repeated offense may result in criminal liability.
