The Committee of Ministers of the Council of Europe has expressed concern regarding the possible disproportionate use of force by the police during assemblies

On June 10-12, 2025, during the session of the Committee of Ministers of the Council of Europe, a decision was adopted on the implementation of the ECHR judgments in the “Mushegh Saghatelyan v. RA” group of cases. 

This group of cases concerns the disproportionate dispersal of peaceful   assemblies, the lack of effective legal remedies in this regard, the persecution of participants, including through dismissals from employment, as well as judicial bias in favor of the police in proceedings related to assemblies. 

  During the years 2020, 2023 and 2025, HCAV, both independently as well as in cooperation with partner organizations, has carried out monitoring of the implementation of the ECtHR judgment in the Mushegh Saghatelyan v. Armenia case under the procedure defined by Rule 9.2 of the Committee of Ministers’ Rules on the supervision of the execution of judgments and of the terms of friendly settlements. 

The Organization has continually recorded and submitted to the Committee of Ministers the cases of illegal and disproportionate use of force by the police during assemblies. 

Despite the regular training sessions and the reforms implemented by the state, the officers of the police still do not have sufficient capacity to ensure the full and unimpeded exercise of this right. In addition, initiating disciplinary proceedings has not produced tangible results. 

Based on the Media publications of 2024, the Organization has recorded 155 cases of human rights violations by the police. In 2023, 122 cases were recorded and 199 cases during 2022. During 2024, 133 cases of human rights violations by police officers were recorded in the time of peaceful assemblies or as a consequence of participation in them, constituting approximately 84.5% of all documented violations.  

The incident of violence against a journalist on 16 June further highlights the systemic problems that the authorities must address with concrete actions. 

In its most recent decision, the Committee of Ministers recommended that the Armenian authorities consider adopting the following additional general measures: 

  High-level messages to promote tolerance for peaceful assemblies 

  A human rights-based approach at all stages of planning, preparing for, and policing assemblies 

Additional trainings for police guard units and other relevant subdivisions on the legal and proportionate use of force during assemblies  

In case of use of force, to ensure automatic and fast reviewing process of the police actions 

The Committee of Ministers also recommended that the authorities provide information on measures taken to address the issue of bias in domestic courts in favor of police testimony in proceedings concerning assemblies (Article 6 § 1).  

  The authorities are obliged to submit to the Committee of Ministers the updated information on the mentioned recommendations and the observations by October 1, 2026.