Civil activist Spartak Tsiklauri was found liable for an administrative offence in connection with a protest held on a sidewalk and was sentenced to 4 days of administrative detention.
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.”
Civil activist Vakhtang Ramishvili was found liable for an administrative offence in connection with a protest held on a sidewalk and was sentenced to 4 days of administrative detention. The decision was issued by Judge Tornike Kapanadze of the Tbilisi City Court. The Ministry of Internal Affairs charged Ramishvili with creating an obstruction for pedestrians on the sidewalk.
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.”
On 22 October 2025, Judge Nino Enukidze of the Tbilisi City Court found civic activist Giorgi Eliashvili liable for an administrative offence on the grounds of failure to comply with a lawful order of the police and imposed an administrative fine of GEL 2,000.
According to available information, the Ministry of Internal Affairs of Georgia alleged that Eliashvili had artificially obstructed a roadway and failed to comply with a lawful police order, namely to leave the road. However, the court established that Eliashvili had not blocked the road and discontinued the proceedings in that part. Notwithstanding this finding, the court nevertheless held him liable for disobedience and imposed the fine.
Proceedings commenced in October 2025 and were postponed on several occasions due to the failure to present evidence. The examination of evidence was concluded in November 2025. Video footage submitted by the defence indicates that, at the time of detention, Eliashvili was standing on the curb and was subsequently moved onto the roadway by police officers. Eliashvili was detained on 22 October 2025.In a social media statement, his lawyer, Boris Chele Kurua, questioned the legal basis for the finding of disobedience, noting that the court itself determined that Eliashvili had not been engaged in the conduct (road blocking) which he was allegedly ordered to cease.
According to civil activist Natia Gabrava, enforcement proceedings were initiated against her and her bank accounts were subjected to seizure due to a fine imposed in connection with a social media post concerning a senior official of the Patrol Police Department, Lasha Salukvadze.
According to the case materials, Gabrava referred to Salukvadze in an offensive manner on social media, following which Salukvadze filed a complaint with the Ministry of Internal Affairs. The case was examined under Article 173(2) of the Code of Administrative Offences, which concerns verbal insult of a law enforcement officer. In November, 2025 Judge Tornike Kochkian of the Tbilisi City Court imposed a fine of GEL 5,000 on Gabrava.
Due to non-payment of the fine, enforcement proceedings were initiated, and the National Bureau of Enforcement imposed seizure on Gabrava’s bank accounts. According to Gabrava, the total amount subject to seizure is GEL 5,350. She further stated that the seized funds included money collected to support the family of a detainee.Gabrava later wrote on social media that the required amount was raised through public support.
Ani Kistauri, an employee of the Media Development Foundation (MDF), was subjected to 2 days of administrative detention. The decision was delivered by Judge Davit Makaradze.
The Ministry of Internal Affairs drew up an administrative offence report against Kistauri for standing on a pavement. The case concerns her presence in front of Parliament on 17 and 18 December 2025 during pro-European protest actions.
During the hearing, the Ministry’s representative, Tekla Kobakhidze, stated that, during Kistauri’s presence at the location, pedestrians were required to move onto the bus lane in order to continue to their destination, which, in her assessment, constituted an obstruction of pedestrian movement. On this basis, she requested that Kistauri be found liable for an administrative offence.
However, the Ministry’s representative did not substantiate the basis on which it was asserted that the individuals who moved onto the bus lane were not protest participants and that their movement had in fact been obstructed, relying instead on her own assessment.
At the stage of the proceedings, defence lawyer Mariam Jikia submitted two motions: first, requesting the termination of the proceedings on the grounds that the relevant legal provision is currently under review before the Constitutional Court, and second, requesting the examination of the patrol inspectors who had drawn up the administrative offence reports. Judge Makaradze dismissed both motion.
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.
