Statements

On 25 June 2026, the European Court of Human Rights communicated to the Government the application lodged by five Georgian civil society organisations concerning the freezing of their bank accounts, thereby commencing the examination of the merits of the case. The applicants are the Social Justice Center, the Civil Society Foundation, the International Society for Fair Elections and Democracy (ISFED), the Institute for Development of Freedom of Information (IDFI), and Sapari. The organisations lodged their application with the European Court on 15 October 2025.

The European Court has granted the application Impact Case status, indicating its preliminary assessment that the case may have a significant impact on the Court's case-law, domestic legislation, and broader human rights and societal issues.

The commencement of the examination of the merits under this procedure sends an important message to the Georgian authorities that any measures aimed at restricting the activities of civil society, criminalising legitimate human rights work, or persecuting independent organisations will be subject to international legal scrutiny and will not remain without an appropriate legal response.

 

1. Factual Background of the Case and Ongoing Domestic Proceedings

As is well known, on 27 August 2025, acting upon a motion filed by the Prosecutor's Office, the bank accounts of seven civil society organisations were frozen. These organisations are the Social Justice Center, Sapari, the Civil Society Foundation, the Institute for Development of Freedom of Information (IDFI), the International Society for Fair Elections and Democracy (ISFED), Democracy Defenders, and the Georgian Democracy Initiative (GDI). According to the Prosecutor's Office, the decision to freeze the organisations' bank accounts was based on their activities and on opinions publicly expressed by their leaders in relation to the mass protests that took place in Tbilisi in 2024.^[1]

The freezing of the bank accounts of the civil society organisations was imposed within the framework of a criminal investigation initiated on 8 February 2025 following a request submitted by United Neutral Georgia. The investigation is being conducted jointly by the Prosecutor's Office, the State Security Service, and the Ministry of Internal Affairs under the following provisions of the Criminal Code of Georgia: Article 318(1) (Sabotage); Article 19 in conjunction with Article 318(2) (Attempted Sabotage committed under aggravating circumstances); Article 319 (Assistance to a Foreign Organisation or an Organisation under Foreign Control in Hostile Activities); and Article 321¹ (Financing or Other Material Support of Activities Directed against the Constitutional Order of Georgia and the Foundations of National Security). These offences are punishable by up to 15 years' imprisonment.

The statements issued by the Prosecutor's Office, as well as the court order imposing the freezing measure, are entirely unsubstantiated. The case file contains no evidence whatsoever capable of substantiating the commission of any criminal offence. During the mass pro-European protests held in 2024, the role of the civil society organisations consisted of documenting grave human rights violations committed by police forces, providing free legal assistance to victims of torture and severe ill-treatment, and representing protesters who had been unlawfully and arbitrarily detained.

In particular, during the protests that were violently dispersed by the police (as documented by the Public Defender,^[2] domestic civil society organisations,^[3] and numerous international organisations^[4] and international monitoring mechanisms^[5]), the purchase of a limited number of items of protective equipment for staff members monitoring assemblies on the ground and for journalists reporting from the scene cannot reasonably be regarded as unlawful conduct. Moreover, the organisations did not procure any prohibited items. All purchases were carried out transparently, in accordance with established internal procedures, and supported by the submission of the relevant documentation to the Revenue Service. This further demonstrates that the organisations acted lawfully and in good faith with the sole objective of safeguarding the occupational safety of their staff members and journalists. Furthermore, numerous international recommendations expressly encourage organisations involved in monitoring and documenting protests to adopt appropriate measures to ensure the safety of their personnel.^[6]

The Prosecutor's Office's assessment that the mass demonstrations held in the spring and autumn of 2024 were, as a whole and without distinction, violent and non-peaceful is deeply concerning and entirely unfounded. Equally unfounded is its position that participation in, or support for, those protests is inherently unlawful. Such conclusions have not been supported by any domestic or international organisation. Isolated incidents involving confrontations between certain protesters and the police must be distinguished from the assemblies as a whole, which remained peaceful. As noted in numerous monitoring reports referred to above, those isolated incidents were frequently precipitated by the actions of the police.

Furthermore, in certain instances, the Prosecutor's Office examined public statements made by the leaders of civil society organisations in connection with the protests. Reliance on those statements in the context of the criminal investigation is likewise unfounded, as every statement and social media post examined by the investigation conveyed exclusively peaceful messages and was protected by the right to freedom of expression. Under Article 10 of the European Convention on Human Rights and Georgian law, interference with freedom of expression,^[7] and, all the more so, criminal prosecution on account of expression, may be justified only in relation to expression that amounts to unlawful incitement to violence and is capable of giving rise to imminent and real acts of violence.^[8] None of the statements made by the leaders of the civil society organisations contained any incitement to unlawful conduct; all consistently advocated peaceful protest.

Accordingly, it is evident that the criminal investigation initiated by the Prosecutor's Office, together with the decision to freeze the accounts of independent and critical organisations with many years of experience in the field of human rights protection, is entirely devoid of factual and legal basis. Rather, these measures pursued the illegitimate objective of criminalising legitimate human rights activities and paralysing the functioning of civil society organisations, ultimately forcing them to cease their operations.

The decision of the Prosecutor's Office was accompanied by a coordinated campaign involving representatives of the ruling party and pro-government propaganda media outlets, including Imedi TV, consisting of the dissemination of disinformation and the promotion of hostile narratives against the organisations.^[9]

Furthermore, following the freezing of the organisations' bank accounts, in September 2025 the Prosecutor's Office summoned, for questioning as witnesses, both former and current leaders of the affected organisations, as well as representatives of other civil society organisations and donor organisations.^[10]

It is noteworthy that the civil society organisations do not have access to the case file and, consequently, remain unaware of the current state and progress of the investigation.

The freezing order has had an extremely severe impact on the organisations, producing a profound chilling effect that is tantamount to their de facto liquidation and paralysis. As a result, the work of the civil society organisations has been significantly weakened, leaving hundreds of individuals without access to free legal assistance and other forms of support. The organisations' research and monitoring activities have likewise been substantially curtailed and weakened, which appears to have been one of the authorities' intended objectives.

The freezing of the assets of the civil society organisations has been strongly condemned by international human rights organisations,^[11] the European Union,^[12] and EU Member States,^[13] as a manifestation of an unfounded criminal investigation and the persecution of civil society.

In his latest report, published in June 2026, the Council of Europe Commissioner for Human Rights concluded that the combined effect of various legislative measures, ongoing administrative and criminal proceedings, and the use of stigmatising rhetoric constitutes a violation of Article 18 of the European Convention on Human Rights. In its October 2025 Resolution, the Parliamentary Assembly of the Council of Europe (PACE) condemned the freezing of the bank accounts of civil society organisations and characterised the measure as amounting to their de facto liquidation. In its June 2026 Resolution, PACE further observed that the existing circumstances pose a threat to the very existence of those organisations.

The freezing order forms part of a broader pattern of systemic repression carried out by the ruling party against civil society. In particular, following the adoption in 2025 of the so-called FARA Law and the entry into force of amendments to the Law on Grants, the Anti-Corruption Bureau initiated inspections against seven organisations and obtained access to information concerning their activities, financial records, and other personal data, including sensitive personal data. In addition, throughout the relevant period, both the organisations and their leaders have repeatedly been subjected to coordinated harassment and persecution by the authorities.

 

2. The Substance of the Application Lodged with the European Court of Human Rights

In their application, the applicant organisations contend that the freezing of their bank accounts violated Article 11 of the European Convention on Human Rights (freedom of association), Article 1 of Protocol No. 1 (protection of property), and Article 18 of the Convention, taken in conjunction with those provisions, which prohibits States from restricting Convention rights for purposes other than those prescribed by the Convention.

The applicant organisations submit that the blanket freezing of their bank accounts, taken together with the ongoing criminal investigation and the questioning of their leaders, constitutes an exceptionally serious interference with their right to freedom of association, notwithstanding their many years of human rights work. As a result of the freezing of their accounts, the applicant organisations' activities have been effectively paralysed. Human rights organisations that had provided free legal assistance to hundreds of individuals each year, monitored elections, combated disinformation, and supported regional civil society groups and independent media have suffered irreparable harm as a result of the freezing of their bank accounts, a measure amounting to their de facto liquidation.

The applicant organisations further submitted to the European Court that neither the Prosecutor's Office, nor the Tbilisi City Court, nor the Tbilisi Court of Appeal produced any evidence establishing a link between the applicants' activities and the criminal offences under investigation or otherwise indicating the commission of any criminal conduct. Furthermore, the domestic courts granted the Prosecutor's Office's applications automatically and without providing any reasoning. Their decisions were manifestly unsubstantiated, superficial, and based on standardised formulaic wording.

The applicant organisations further argue that the freezing of their bank accounts constituted an interference with their right to the peaceful enjoyment of their possessions under Article 1 of Protocol No. 1 to the Convention. They submit that this interference was unlawful, pursued no legitimate aim, and was disproportionate.

With regard to Article 18 of the Convention, the applicants further contend that the true purpose underlying the restrictions imposed on their Convention rights was to dismantle critical civil society organisations. In support of this allegation of an ulterior purpose, the organisations relied on a range of circumstances, including the adoption in recent years of legislation aimed at restricting and suppressing civil society in Georgia and its arbitrary enforcement against selected organisations; the dismantling of all mechanisms for cooperation and consultation with civil society organisations; and sustained campaigns of discreditation and harassment directed against civil society leaders by the authorities and media outlets under their control. 

The application further submits that the Prosecutor's Office lacks institutional independence and operates as an instrument of the ruling party. It also notes that both the current and former Prosecutors General have been sanctioned by the United States, the United Kingdom, the Czech Republic, Estonia, and Lithuania for serious human rights violations.

Finally, the application places the impugned measures within the broader context of democratic backsliding in Georgia. It refers, inter alia, to the 2024 parliamentary elections, which were neither free nor fair; the suspension of Georgia's European Union accession process; the systemic practice of arbitrary detention and widespread ill-treatment of protesters; the dismissal of hundreds of pro-European public servants; the abolition or weakening of independent oversight bodies and government institutions responsible for European integration; the significant legislative deterioration of civil and political rights; and other related developments.

 

3. Questions Put to the Government by the European Court in the Proceedings

The European Court took into account all of the applicants' submissions and decided to communicate the application in respect of all three Convention provisions relied upon, thereby accepting the case for examination on the merits. The Court put questions to the parties and granted the Government of Georgia until 15 October to submit its observations.

In particular, the Court asked whether the respondent State had violated Article 11 of the Convention (freedom of association) and Article 1 of Protocol No. 1 (protection of property) by freezing the applicant organisations' bank accounts. In this regard, the Court requested the Government to specify the concrete facts and evidence on the basis of which the domestic authorities—namely, the prosecuting authorities and the domestic courts—concluded that the applicant organisations might have been involved in criminal activity. More specifically, the Court asked what facts or evidence gave rise to a reasonable suspicion that the applicant organisations had provided material, financial, or any other form of support to persons participating in the mass protests. The Court also requested information as to whether the applicant organisations' bank accounts remain frozen. In addition, it sought clarification regarding the current status of the criminal investigation and any further factual developments relating to the applicant organisations.

Furthermore, the Court raised a question under Article 18 of the Convention, specifically requesting the Government to explain whether the restrictions imposed on the applicant organisations under Article 11 of the Convention were applied for purposes other than those prescribed by that provision, thereby giving rise to a violation of Article 18 of the Convention.

 

Conclusion

The repressive legislative framework and administrative measures adopted by Georgian Dream have had a profoundly adverse impact on the existence and functioning of a democratic, independent, and pluralistic civil society in Georgia. Throughout Georgia's modern political and constitutional development, civil society has played a central role in ensuring democratic oversight, public accountability, the protection of human rights, and meaningful public participation. Accordingly, arbitrary State interference with the activities of civil society affects not only the rights of individual organisations but also the overall quality of democratic governance, the protection of human rights, and the pluralism of the public sphere.

Legislative amendments and their practical implementation have significantly deteriorated the operating environment for civil society organisations. As a consequence, a number of organisations have reduced the scope of their activities, altered their operational models, or ceased working in certain areas altogether. At the same time, organisations actively engaged in the protection of human rights, the monitoring of government policies, public interest advocacy, and critical public discourse have been subjected to particularly intensive restrictive measures and pressure.

The arbitrary, aggressive, and highly repressive interference by the authorities with the activities of specific organisations has affected not only the direct victims of those measures but also the civil society sector as a whole. In its case-law, the European Court of Human Rights has repeatedly emphasised that restrictive measures imposed by the State may produce a broader chilling effect, where the risk of sanctions or interference discourages other individuals and organisations from exercising their rights, encourages self-censorship, or leads to a reduction in public participation. Within the context of civil society, such an effect is particularly serious, as it undermines the very essence of freedom of association and weakens the mechanisms of democratic oversight and civic participation.

Accordingly, the present case extends well beyond the assessment of an individual violation. The judgment of the European Court may have significant implications for the effective protection and restoration of the rights of civil society organisations in Georgia, as well as for safeguarding their institutional independence.

 

The applicant organisations will continue to keep the public regularly informed of developments in the proceedings before the European Court. 

---

^[1] According to the Prosecutor's Office, the decision was based on allegations that, during the pro-European mass protests held throughout 2024, the leaders of the organisations had called for mass civil disobedience and universal resistance, paid administrative fines imposed on alleged offenders, provided legal assistance, and used NGO funds to equip protesters who allegedly engaged in violent acts against law enforcement officers with protective equipment. The Prosecutor's Office further alleged that the organisations had acted beyond the scope of their statutory objectives and had used a significant portion of the funds received to finance unlawful activities. On the basis of these allegations, and pursuant to a court order, the organisations' bank accounts were frozen in order to prevent what the Prosecutor's Office described as the further "misuse of funds." Statement of the Prosecutor's Office of Georgia, 27 August 2025, available at: https://pog.gov.ge/news/saqartvelos-prokuraturis-gantskhadeba-4982

^[2] Public Defender of Georgia, Parliamentary Report 2024, available at: https://ombudsman.ge/geo/saparlamento-angarishebi

^[3] Joint Report of Civil Society Organisations, Human Rights Crisis in Georgia Following the 2024 Parliamentary Elections, available at: https://socialjustice.org.ge/ka/products/adamianis-uflebebis-krizisi-sakartveloshi-2024-tslis-saparlamento-archevnebis-shemdgom

^[4] OSCE Fact-Finding Mission on Georgia (2026) under Paragraph 12 of the Moscow Mechanism Document, Report on Developments in Georgia in Respect of Human Rights and Fundamental Freedoms since Spring 2024, by Professor Patrycja Grzebyk, Sole Rapporteur, available at:
https://odihr.osce.org/sites/default/files/documents/official_documents/2026/03/odgal0009c1%20ODIHR%20NV%2082-2026%20report_Moscow%20Mechanism%20invoked%20in%20respect%20of%20Georgia_0.pdf

^[5] Amnesty International, Georgia: Authorities Built Coordinated System to Crush Dissent and Entrench Power, 15 June 2026, available at: https://www.amnesty.org/en/latest/news/2026/06/georgia-authorities-built-coordinated-system-to-crush-dissent-and-entrench-power/

^[6] OSCE Office for Democratic Institutions and Human Rights (ODIHR), Handbook on Monitoring Freedom of Peaceful Assembly, Second Edition, 11 December 2020, available at: https://odihr.osce.org/odihr/monitoring-peaceful-assembly; Reporters Without Borders (RSF), Safety Tips for Journalists Covering Protests, 30 November 2022, available at: https://safety.rsf.org/safety-tips-for-journalists-covering-protests/

^[7] Özgür Gündem v. Turkey, § 63.

^[8] See, for example, Brandenburg v. Ohio, 395 U.S. 444 (1969); Law of Georgia on Freedom of Speech and Expression, Article 4.

^[9] Imedi TV, "The 'Grant Revolution' That Never Happened": Report by Imedi Week, 7 September 2025, available at: https://imedinews.ge/ge/politika/401538/ver-shemdgari-grantebis-revolutsia-imedis-kviris-reportaji

^[10] Statement of the Prosecutor's Office of Georgia, 1 September 2025, available at: https://pog.gov.ge/news/saqartvelos-prokuraturis-gantskhadeba-4989

^[11] The Observatory for the Protection of Human Rights Defenders (a partnership of the International Federation for Human Rights (FIDH) and the World Organisation Against Torture (OMCT)), Georgia: Tbilisi City Court Freezes Bank Accounts of Seven Further Leading Civil Society Organisations amid Unfounded Investigations for "Sabotage", 29 August 2025, available at: https://www.omct.org/en/resources/urgent-interventions/georgia-tbilisi-city-court-freezes-bank-accounts-of-seven-further-leading-civil-society-organisations-amid-unfounded-investigations-for-sabotage; See also Amnesty International, Georgia: Authorities Built Coordinated System to Crush Dissent and Entrench Power, 15 June 2026, available at: https://www.amnesty.org/en/latest/news/2026/06/georgia-authorities-built-coordinated-system-to-crush-dissent-and-entrench-power/

^[12] Delegation of the European Union to Georgia, Georgia: Statement by the Spokesperson on the Decision of the Authorities to Freeze the Bank Accounts of Seven Civil Society Organisations, 29 August 2025, available at: https://www.eeas.europa.eu/eeas/

^[13] PalitraNews, Czech Ministry of Foreign Affairs: "Non-Governmental Organisations Play an Irreplaceable Role in Every Country — We Call on the Government of Georgia to Halt the Investigations and Unfreeze the Frozen Financial Resources", 25 August 2025, available at: https://palitranews.ge/v/265046/