Civil activist Mariam Kipiani was subjected to 2 days of administrative detention for standing on a pavement. The decision was delivered by Judge Davit Makaradze.
During the hearing, the representative of the Ministry of Internal Affairs, Tekla Kobakhidze, stated that, during the protest, Kipiani was standing in front of Parliament with the intention of deliberately obstructing pedestrian movement. She further indicated that demonstrators had occupied the pedestrian walkway and were expressing their protest in this manner. She requested that Kipiani be found liable for an administrative offence; however, she did not specify where the protest could have been conducted, given that, under the applicable legislation, blocking a roadway is sanctioned in a similar manner.
At the hearing, the Ministry presented surveillance footage from 112, showing several individuals moving from the pavement onto the bus lane while passing near Parliament. According to the Ministry’s representative, these individuals were not participants in the protest and had to move onto the bus lane because the pavement was fully occupied.
The defence asked whether these individuals had raised any complaints, to which the Ministry’s representative responded that no communication had taken place with them. When asked on what basis it was asserted that they were not protest participants and that their movement had been obstructed, Kobakhidze stated: “I am certain.”
Civil activist Mariam Melikishvili was subjected to 2 days of administrative detention for standing on a pavement. The decision was delivered by Judge Manuchar Tsatsua. The Ministry of Internal Affairs alleged that, on 18 December 2025, Melikishvili obstructed pedestrian movement on the pavement.
On 31 March, civic activist Mariam Melikishvili reported a on social media that, in the context of serving a 2-day administrative detention imposed on 27 March, she was requested to fully undress prior to her placement in a temporary detention facility. According to her account, following her transfer from the courtroom to a temporary holding cell, a female police officer instructed her to fully undress. The activist further stated that she was informed that, in case of refusal, the same procedure would be carried out by male officers upon her transfer to another facility. Despite this, she refused to comply with the request.
It is noteworthy that multiple detainees have reported similar practices. The Public Defender of Georgia has stated that, during full-body searches, individuals should not be required to undress different parts of their body simultaneously, and that such practices may amount to degrading and humiliating treatment.On 5 February 2025, the Public Defender filed a constitutional complaint before the Constitutional Court of Georgia, challenging the regulations governing penitentiary institutions that required detainees to fully undress during searches. Subsequently, on 10 June 2025, amendments were introduced by order of the Minister of Justice, abolishing the requirement for detainees to fully undress simultaneously during such procedures.
Administrative proceedings against citizens in relation to sidewalk protests commenced following legislative amendments adopted by Georgian Dream 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, 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.”
Levan Zhvania, a civil activist, was subjected to 4 days of administrative detention. The Ministry of Internal Affairs alleged that he was standing on the roadway during protest actions.
According to Zhvania’s lawyer, the video evidence presented in the case file does not substantiate that his client committed any violation. He stated that Zhvania was present at a protest and participating in an assembly, and that, in the defence’s assessment, his conduct did not exceed the limits permitted by law.
On 16 October 2025, Georgian Dream adopted legislative amendments to the Criminal Code of Georgia and the Code of Administrative Offences of Georgia, which significantly restrict the forms through which demonstrators may express peaceful protest. Under these amendments, Article 174¹ of the Code of Administrative Offences was supplemented with paragraph 10, providing that participants in assemblies and demonstrations shall be subject to mandatory administrative detention for certain acts. These include, inter alia, covering one’s face with a mask or other means, possessing tear gas or similar substances, intentionally creating obstacles to pedestrian or vehicular movement, installing temporary structures, or partially or fully blocking a roadway.
A violation of this provision is punishable by administrative detention for up to 15 days, or up to 20 days in the case of an organizer. The amendments also introduced changes to the Criminal Code of Georgia, providing that the repeated commission of the above-mentioned acts within a one-year period may result in criminal liability.
At the Tbilisi City Court, three hearings were held in cases related to the alleged obstruction of a roadway and pavement during protest actions near Parliament. In these cases, the court applied different sanctions – one individual was subjected to administrative detention, while two were issued verbal warnings.
Mariam Madzgharashvili was subjected to 2 days of administrative detention by Judge Nino Enukidze. Nika Beridze and Mikheil Nakheuri were issued verbal warnings by Judge Tornike Kapanadze.
Paata (Tato) Alaverdashvili, a civil activist and psychotherapist, was subjected to 4 days of administrative detention by Judge Manuchar Tsatsua.
The case differs from the majority of recent administrative proceedings brought against participants in protest actions – Alaverdashvili was held liable for an administrative offence involving the alleged insult of a police officer. The case concerns an alleged gesture of showing a middle finger to a police officer. The court held several hearings before delivering its decision.
According to Alaverdashvili, on 8 March, during a protest in front of Parliament, he noticed an individual in civilian clothing filming demonstrators. He perceived the person as a provocateur, began recording himself, and called on the individual to lower the car window. According to his account, when the individual did not do so, he expressed dissatisfaction through a gesture. It later became known that the individual was a police officer.
Paata Alaverdashvili was detained late at night on 9 March while returning from a protest, and an administrative offence report was drawn up against him. According to Davit Chkheidze, while Alaverdashvili was travelling in a vehicle together with Chkheidze’s family, patrol police stopped the vehicle and conducted an alcohol test. In parallel, Alaverdashvili was removed from the vehicle and detained on the spot on the grounds of allegedly insulting a police officer, while Chkheidze himself was taken for narcological testing.
Sesili Butkhuzi was subjected to 3 days of administrative detention on the grounds of standing on a pavement. The decision was issued on 25 March by Judge Manuchar Tsatsua.
According to the Ministry of Internal Affairs, Butkhuzi was accused of creating an obstruction to pedestrian movement by standing on the pavement in front of Parliament on 18 December 2025. The first hearing in her case was held on 29 December 2025, after which the proceedings were postponed multiple times.
Representatives of the Ministry of Internal Affairs, Butkhuzi’s lawyer, and Butkhuzi herself were not present at the hearing. She learned of the decision in the courtyard of the court, after which she contacted the emergency service and informed law enforcement of her location. She will spend the next 3 days in a temporary detention isolator in Baghdati.
Administrative proceedings against citizens in relation to sidewalk protests commenced following legislative amendments adopted by Georgian Dream 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, 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.”
Levan Khmiadashvili, an energy specialist and civil activist, was found liable for an administrative offence on the grounds of allegedly blocking a roadway during protest marches; however, Judge Manuchar Tsatsua limited the sanction to a verbal warning. Khmiadashvili was accused of blocking a roadway during protest marches held on 31 January and 7 February. According to his lawyer, despite the court limiting the sanction to a verbal warning, the finding of liability itself remains unsubstantiated.
Khmiadashvili stated that he had expected administrative detention, noting that such a sanction is typically imposed in similar cases. He further stated that protest marches and brief gatherings in front of Parliament should not result in repeated court proceedings or be used as a mechanism of pressure against citizens.
On 16 October 2025, Georgian Dream adopted legislative amendments to the Criminal Code of Georgia and the Code of Administrative Offences of Georgia, which significantly restrict the forms through which demonstrators may express peaceful protest. Under these amendments, Article 174¹ of the Code of Administrative Offences was supplemented with paragraph 10, providing that participants in assemblies and demonstrations shall be subject to mandatory administrative detention for certain acts. These include, inter alia, covering one’s face with a mask or other means, possessing tear gas or similar substances, intentionally creating obstacles to pedestrian or vehicular movement, installing temporary structures, or partially or fully blocking a roadway.
A violation of this provision is punishable by administrative detention for up to 15 days, or up to 20 days in the case of an organizer. The amendments also introduced changes to the Criminal Code of Georgia, providing that the repeated commission of the above-mentioned acts within a one-year period may result in criminal liability.
On 25 March, by a decision of the Tbilisi City Court, Lasha Katsia, an active participant in ongoing protests, was subjected to 4 days of administrative detention. The decision was issued by Judge Tornike Kapanadze. According to the Ministry of Internal Affairs, he allegedly blocked a roadway on Rustaveli Avenue on 7 February.
Lasha Katsia is the brother of Nika Katsia, who was held in pre-trial detention from 7 December 2024 until 3 September 2025, when the court found him not guilty and ordered his release in the courtroom. Nika Katsia stated that his detention was related to his participation in protest activities.
On 16 October 2025, Georgian Dream adopted legislative amendments to the Criminal Code of Georgia and the Code of Administrative Offences of Georgia, which significantly restrict the forms through which demonstrators may express peaceful protest. Under these amendments, Article 174¹ of the Code of Administrative Offences was supplemented with paragraph 10, providing that participants in assemblies and demonstrations shall be subject to mandatory administrative detention for certain acts. These include, inter alia, covering one’s face with a mask or other means, possessing tear gas or similar substances, intentionally creating obstacles to pedestrian or vehicular movement, installing temporary structures, or partially or fully blocking a roadway.
A violation of this provision is punishable by administrative detention for up to 15 days, or up to 20 days in the case of an organizer. The amendments also introduced changes to the Criminal Code of Georgia, providing that the repeated commission of the above-mentioned acts within a one-year period may result in criminal liability.
On 25 March, Amiran Urushadze, a sumo commentator and civil activist, was subjected to 4 days of administrative detention on the grounds of allegedly blocking a roadway. The decision was issued by Judge Tornike Kapanadze.
According to Urushadze’s lawyer, Mikheil Zakareishvili, the only evidence presented by the Ministry of Internal Affairs shows that Urushadze briefly stepped onto the roadway for a few seconds in order to listen to a police officer’s statement, after which he returned to the pavement.
According to the lawyer: “He stepped onto the roadway to listen to the police officer, not to block the road. Despite this, Judge Tornike Kapanadze imposed 4 days of detention. The reasoning for the decision is not known at this stage – the ruling has only recently been served, and its justification will become clear upon review.”
On 16 October 2025, Georgian Dream adopted legislative amendments to the Criminal Code of Georgia and the Code of Administrative Offences of Georgia, which significantly restrict the forms through which demonstrators may express peaceful protest. Under these amendments, Article 174¹ of the Code of Administrative Offences was supplemented with paragraph 10, providing that participants in assemblies and demonstrations shall be subject to mandatory administrative detention for certain acts. These include, inter alia, covering one’s face with a mask or other means, possessing tear gas or similar substances, intentionally creating obstacles to pedestrian or vehicular movement, installing temporary structures, or partially or fully blocking a roadway.
A violation of this provision is punishable by administrative detention for up to 15 days, or up to 20 days in the case of an organizer. The amendments also introduced changes to the Criminal Code of Georgia, providing that the repeated commission of the above-mentioned acts within a one-year period may result in criminal liability.
On 19 March, information was disseminated that Shalva Esartia, an activist detained in Zugdidi, was being held under criminal, rather than administrative, proceedings, which was later confirmed by his lawyer, Ramaz Mikaia. According to him, Esartia was charged under Article 353³ of the Criminal Code, which concerns the repeated commission of the same act by a person who has already been subject to an administrative sanction and provides for imprisonment of up to one year.
On 20 March, Judge Ekaterine Bebia of the Zugdidi District Court imposed pre-trial detention as a preventive measure on Shalva Esartia, who had been detained on charges of disobedience to a police officer.
Shalva Esartia was detained on 17 March. His detention was preceded by being stopped while driving, which, according to the “Civil Solidarity Fund”, occurred on the purported grounds of failing to yield to a pedestrian. Esartia denied committing any offence, stating that he had not violated traffic rules. Footage disseminated on the same day shows police officers using force to place him into a patrol police vehicle.
According to the organisation, the shift from an initial administrative charge to criminal proceedings raises indications of selective enforcement and may be linked to his activism. Esartia has been detained for the third time on charges of disobedience to a police officer — in previous instances, he was first fined and subsequently subjected to administrative detention, whereas the present case is being pursued under criminal law.
The provision of the Criminal Code under which repeated disobedience to or insult of a police officer is punishable by up to one year of imprisonment was introduced in Parliament by “Georgian Dream” on 13 October 2025 and adopted under an accelerated procedure within two days.
