The Council of Europe’s Committee of Ministers, which oversees the implementation of the European Court of Human Rights rulings, published its annual report on March 25, according to which in 2025, it received eleven new cases from the ECtHR against Georgia, while 77 cases were pending execution. Seven cases were closed, full payment of just satisfaction was confirmed in nine, and delays were reported in five.
According to the report, the 11 new cases received from the Court for supervision of their execution were slightly fewer than 13 in 2024 and 15 in 2023. “Of the new violations found by the Court in 2025, most of them concerned the excessive length of judicial proceedings and issues related to freedom of assembly,” the report said, adding, “One new case concerned the excessive use of force by the police during the dispersal of a demonstration.”
By the end of 2025, 77 cases were pending implementation, compared to 73 in 2024 and 78 in 2023. Of these, nine leading cases were classified under the “enhanced procedure,” while 20 were under the “standard procedure.” According to the report, “Of the leading cases under enhanced procedure, five have been pending for five years or more; similarly, nine of the leading cases under standard procedure have been pending for five years or more (compared to nine in 2024 and eight in 2023).”
According to the report, since Georgia ratified the European Convention on Human Rights, a total of 202 cases have been brought before the Committee of Ministers, including 82 leading and 120 repetitive cases.
Actions Plans/Reports
In 2025, the Georgian authorities submitted seven action plans and 15 action reports to the Committee of Ministers. Updates were still awaited in four groups/cases where feedback had been provided before the start of the year.
Just satisfaction
Full payment of just satisfaction was confirmed in nine cases in 2025. However, confirmation of payment and/or default interest remained pending in five cases, “for which the deadline indicated in the Court’s judgment has passed since more than six months.”
Closures, Main Achievements
The Committee of Ministers closed seven cases against Georgia in 2025, including two leading cases under “standard supervision.”
One of these concerned “the violation of the right to respect for family life, following the evolution of judicial practice related to the best interests of the child in proceedings under the 1980 Hague Convention on the civil aspects of international child abduction.”
The report added that “five repetitive cases were closed because no further individual measures were necessary or possible.”
Main Examined Issues
The annual report said that throughout 2025, the Committee of Ministers examined and adopted decisions on five leading cases/groups “under enhanced procedure.”
- The Tsintsabadze group of cases concerned the “lack of effective investigations into allegations of ill-treatment or violations of the right to life; excessive use of force by the police in the course of arrest and/or while detaining suspects.”
- The Merabishvili case highlighted the “failure by the domestic courts to give relevant and sufficient reasons to justify continuation of detention on remand; continued detention on remand with predominant purpose of obtaining information from the applicant about third persons.”
- A.D. and Others case showed “the lack of legislation governing procedures for legal gender recognition.”
- The Identoba and Others group of cases pointed to “the lack of protection against homophobic attacks or religiously motivated attacks.”
- Makarashvili and Others Case, concerned “violations of the rights to freedom of assembly and fair trial on account of administrative convictions in the context of demonstrations, and violation of the right to liberty and security on account of arbitrary administrative arrest and detention.”
The report noted that the pending caseload includes notably cases concerning “the failure to take preventive action regarding domestic violence and the failure to investigate the law-enforcement authorities’ inaction; the length of judicial proceedings and the absence of an effective remedy in this respect; the right to a fair trial and the impartiality of a tribunal.”
Interstate Cases Involving Russia
Georgia is also referenced in the context of interstate and conflict-related cases against Russia. These include one case concerning “the arrest, detention and expulsion from the Russian Federation of large numbers of Georgian nationals” between September 2006 and January 2007, and another “concerning various violations of the Convention in the context of the armed conflict between the Russian Federation and Georgia in August 2008.”
The report said that the Committee of Ministers “exhorted the Russian authorities to abide fully, effectively, and promptly by the final judgments of the European Court and insisted again firmly on the unconditional obligation of Russia to pay without further delay the just satisfaction amounts awarded by the European Court along with the interest accrued.”
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