European Court Finds No Violation in Georgian Activist's TikTok Fine
By Messenger Staff
Thursday, May 21, 2026
The European Court of Human Rights ruled on May 19 that Georgia did not violate freedom of expression when it fined activist Irakli Miladze in 2023 over a viral TikTok video in which he used profane language toward public officials, finding the interference with his expression "necessary in a democratic society."
The case concerned a December 2022 TikTok video in which Miladze used profane language directed at Tbilisi Mayor Kakha Kaladze and staff of Tbilisi City Hall and Interior Ministry officials, criticizing urban transport policies and what he viewed as arbitrary exemptions for law enforcement officers from traffic regulations. He was convicted in March 2023 on charges of disorderly conduct and insulting a law enforcement officer and fined GEL 2,000. On appeal, the Tbilisi Court of Appeal reduced the fine to GEL 500 and dismissed the second charge as unsubstantiated.
In its judgment, the ECHR pointed to several factors in finding no violation, including "the particularly aggressive nature of the vulgar language used," the video's extensive dissemination on a platform aimed at young people, the thoroughness of the balancing exercise conducted by Georgian courts, and, crucially, the limited severity of the sanction. The court noted that Miladze was fined the minimum amount of GEL 500, that no criminal proceedings were instituted, that he received no custodial sentence, and that authorities did not seek removal of the video or any broader censorship. "Such a limited severity of the sanction is indeed an important factor in the proportionality assessment," the court said.
The Georgian Young Lawyers Association, which represented Miladze, said the ruling nonetheless "clearly defines the guiding standard that in no way allows the Ministry of Internal Affairs to pursue a coordinated practice of persecuting free expression." The group argued the judgment was directly relevant to the current situation, which it described as a "severe human rights crisis" in which "freedom of expression is a primary target of repression."
GYLA said that by 2025, administrative offense proceedings against individuals on grounds of insult had "become routine for the Interior Ministry," with penalties ranging from GEL 1,500 to GEL 4,000 or up to 45 days in detention for six offenses, and repeat offenses carrying fines of GEL 2,500 to GEL 6,000 or detention from five to 60 days. The watchdog said the ECtHR judgment establishes that sanctions "must not be severe or disproportionate," that proceedings "must not carry a real risk of detention," and that authorities must not restrict expression through dissemination measures.
GYLA also noted that the ruling came a day after Georgian Dream announced plans to establish a special Interior Ministry unit to "systematically monitor" hate speech and aggressive communication in public spaces. "The creation of such a police mechanism poses a direct threat to freedom of expression and raises risks of political censorship and total control," the group said.
