Election Fraud Allegations: Legal Standards and Realities Based on the 2024 Parliamentary Elections of Georgia

13 October 2025

Lilu Chkhartishvili, Year 2 Law Student

I. Introduction

Election fraud allegations have been disputed for a long time in democratic societies, especially developing countries and states prone to authoritarian rule. While electoral processes aim to uphold the principles of transparency and fairness, accusations of election fraud can challenge the legitimacy of election outcomes and fuel political instability and polarization. In the case of Georgia’s 2024 parliamentary elections, allegations of electoral fraud have sparked widespread public dissent and demand for new elections overlooked by external actors. This blog explores the legal standards for evaluating election fraud claims, the realities of such allegations in Georgia, and the broader implications for democracy.

II. The 2024 Parliamentary elections of Georgia

A.    Build-up to the Elections

The dissolution of the Soviet Union freed Georgia from the shackles of totalitarian rule. The newly gained independence opened doors for democratic development for the emerging sovereign state. However, the path towards democratization has been patchy and inconsistent: “never fully democratized, yet never completely failing.”[1] After a period of darkness and the grimness of civil war, the late prime minister Zurab Zhvania spoke words of hope and aspirations in front of the Council of Europe in 1999: “I am Georgian and therefore I am European.”[2] This was an expression of Georgian people’s choice, a track towards the west, an agenda for a future in the European Union. Later, this aspiration was even put in the constitution: “The constitutional bodies shall take all measures within the scope of their competences to ensure the full integration of Georgia into the European Union and the North Atlantic Treaty Organization.”[3] Integration into Western institutions is considered the only viable way to counter the Russian threat and safeguard Georgia’s sovereignty.[4] 

Georgia’s slow steps towards EU candidacy seemed promising, although disapproval towards the ruling party existed in the public. However, after the invasion of Ukraine in 2022, Georgia’s political trajectory shifted significantly. Georgian Dream, holding a majority in the parliament, introduced the “foreign agent’s law” in 2024, which aims to govern the transparency of foreign influence and targets non-governmental organizations. It should be noted that the law’s first introduction failed amid public outrage in 2023.[5] The government even overruled the President’s veto, which fueled public tension even more.[6] The introduced law was labeled as “Russian”, because of the resemblance to an authoritarian bill that came into force in Russia in 2012 and the biggest concern was that the government would use this legislation to suppress its opponents and civil organizations, that monitor and often unmask the wrong-doings and irregularities of the ruling party.[7] Protests against the passing of the law took a surprising turn, as the peaceful protesters were confronted with disproportionate force and arbitrary arrests. This motivated the people to take to the streets daily and demand the abolishment of the Russian law and for the government to revert to democratization.[8] As people’s voices were not heard, all they could do was wait for the elections to change the government in a democratic, fair, and peaceful way.[9] Concerns regarding electoral fraud, which had been noticed in previous elections, pushed people to massively sign up as observers to monitor the transparency of the proceedings.

B.    The Elections and Followed Allegations

The awaited elections took place on October 26, 2024, with the highest percentage of activity after 2012 being 58.94%.[10] International, independent and local observers were reporting from all over Georgia and the electoral precincts in 42 countries the whole day. The process was more transparent in major cities, with fewer irregularities noted in contrast to regions, especially populated with ethnic minorities.[11] The expectations for the outcome of exit polls were high. Edison Research’s exit polls gave the Georgian Dream 40.9%, with the opposition gaining 51.9% of votes in total, with a +/- 2.5% margin of error for a 95% confidence level.[12] The celebration of the European future for Georgia came short after the Central Election Commission shared the final official results of the ruling Georgian Dream party’s 54 % victory.[13] 

The dramatic 13% difference between the exit polls and official election results brought shock and disappointment to the public and the opposition parties. Suspicions of vote manipulation grew stronger and more substantive.[14] This was followed by a number of organizations gathering reports of abnormalities and irregularities on the electoral precincts.

On November 5, the International Society for Fair Elections and Democracy (ISFED) published an evaluation of the 2024 elections, detailing all inconsistencies and misconduct reported.[15] On November 14, the opposition Coalition for Change, which obtained the most votes among other opposition coalitions, presented a document detailing evidence of electoral fraud, with hundreds of filed complaints describing the violations present at electoral venues.[16] The only hope and issue left was the OSCE/ODIHR Election Observation Mission Final Report, which would showcase the standing of the most important observers and the legitimacy of the election outcomes.

III. Legal standards for voting rights and election fraud

A.     Legal Standards Established by International and Regional Bodies

The legal standards governing the right to vote stem from international treaties and regional human rights frameworks. The International Covenant on Civil and Political Rights (ICCPR) and the European Convention on Human Rights (ECHR), including Protocol 1, all ratified by Georgia, set out fundamental rights and obligations for democratic elections.[17] In addition, various international organizations, including the Organization for Security and Co-operation of Europe (OSCE), the Council of Europe, and the United Nations, provide further guidance on election integrity, electoral fraud, and dispute resolution.

Article 25 of the ICCPR specifically protects the right to vote and to participate in public affairs.[18] It provides that: “Every citizen shall have the right and the opportunity, without any of the distinctions mentioned in Article 2 and without unreasonable restrictions: […] (b) To vote and to be elected at genuine periodic elections which shall be by universal and equal suffrage and shall be held by secret ballot, guaranteeing the free expression of the will of the electors.”[19] This provision is further clarified in General Comment No. 25 of the UN Human Rights Committee, which elaborates on the scope of electoral rights under the ICCPR.[20] Elections must be genuine, periodic, and free, with universal suffrage prohibiting any form of voter suppression. Where restrictions are imposed, they must be both reasonable and proportionate. Equal suffrage demands that all votes carry equal weight, while the secret ballot serves as a safeguard to ensure voters are free from coercion and can express their will independently. The Committee also strongly recommends international election monitoring to support integrity of electoral processes.[21] Violations of Article 25 could include voter intimidation, vote-buying, manipulation of electoral rolls, and ballot fraud.

The ECHR, adopted by the Council of Europe, provides a binding legal framework for electoral rights through Protocol No. 1. Article 3 of the Protocol states: „The High Contracting Parties undertake to hold free elections at reasonable intervals by secret ballot, under conditions which will ensure the free expression of the opinion of the people in the choice of the legislature”[22] Similar to Article 25 of the ICCPR, this provision requires elections to be free, held at regular intervals, and conducted by secret ballot to safeguard voters’ freedom of expression.[23] In addition to the Convention itself, the case law of the European Court of Human Rights (EctHR) has developed core democratic principles and ruled on numerous election fraud cases. Instances of failure to ensure a transparent election process, exclusion of candidates, and manipulation of results have been found to violate Article 3 of Protocol No. 1.[24] Other violations of this provision include ballot fraud, government interference in electoral process, and suppression of opposition candidates.

OSCE sets additional election standards through several key instruments, including the 1990 Copenhagen Document, which requires elections to be free, fair, and democratic; the OSCE/ODIHR Election Observation Handbook, which provides a framework for detecting and preventing election fraud; and the Venice Commission Code of Good Practice in Electoral Matters, which ensures effective dispute resolution.

Most of the fundamental commitments related to elections are contained in the 1990 OSCE Copenhagen Document, which reflects and upholds the same principles set out in Article 25 of the ICCPR. The OSCE requires that the electoral framework of participating states is applied in a manner that guarantees universal and equal suffrage; the right of citizens to seek public office; the casting of votes by secret ballot; that votes are counted and reported honestly, with the results made public; and that candidates who receive the necessary number of votes are duly installed in office.[25] 

OSCE/ODIHR outlines eight core principles that apply to both the legislative framework and the practical administration of elections: integrity, legality, effectiveness, independence, impartiality, transparency, accountability, and inclusivity.[26] Analysts from ODIHR election observation missions and long-term observers assess whether election administrations and election management bodies adhere to these principles in implementation of the electoral legislation.[27] 

The Handbook for the Observation of Election Dispute Resolution guides ODIHR election observation missions in assessing how election disputes are resolved as part of the broader election observation process. It combines explanations of guiding principles with international standards for election dispute resolution (EDR).[28] The handbook outlines Core Procedural Principles, which underpin effective EDR. They are the commitments of OSCE participating states: genuine opportunity to present one’s case, independence, impartiality, transparency, legality and legal certainty, and accessibility. In short, OSCE establishes that EDR requires a fair trial for all election fraud cases, demands that access to legal remedies be guaranteed with timeliness and due process, and upholds that courts must provide clear justifications for their rulings.[29]

Specific Considerations for Different Election Disputes in the Electoral Process provides an overview of common complaints and appeals encountered at different stages of the electoral process – pre-election, election day, and post-election. The handbook does not provide an exhaustive list of all possible grievances. Pre-election complaints and appeals usually involve the delimitation of electoral boundaries, voter registration, campaigning and campaign financing, election administration, new voting technologies, and media. Election-day complaints and appeals cover voter identification and voter lists, violations of election day procedures, and breaches of electoral silence. Finally, the post-election appeals often involve complaints that challenge the results of an entire constituency or nationwide.[30] The Venice Commission’s Election Dispute Resolution recommends independent electoral courts to review fraud cases, quick and efficient complaint procedures to avoid delays, and public transparency. [31]

B.    Local Regulation of Election Fraud

“Every citizen of Georgia who has attained the age of 18 shall have the right to participate in referendums and elections of the bodies of the state, autonomous republics, and local self-governments. The free expression of the will of a voter shall be guaranteed.”— Article 24 of the Georgian Constitution.[32] 

Georgia has its own Election Code, which is part of the Organic Law of Georgia. It regulates relations connected with the preparation and conduct of referenda, plebiscites, and elections. [33] The Electoral Administration of Georgia is an independent administrative body. Its main representative is the Central Election Commission (CEC), which is responsible for organizing national elections.[34] CEC addresses complaints and appeals related to electoral violations, ensuring that legal procedures are adhered to following the election code.[35]  Penalties for Violation of Electoral Legislation are discussed in paragraph 10, like ‘Restriction of rights for observers, electoral subjects, and media representatives’; the code imposes a penalty on the respective persons in violation with the amount of GEL 500.[36] Based on the complaints of CEC observers, independent observers or voters, the CEC can annul the results of voting in precincts or in an overall election. [37]

Most of the violations connected to election fraud are regulated and prosecuted under the Administrative Offenses Code of Georgia and, most importantly, the Criminal Code of Georgia. Interference with the expression of will in the elections, referendum, or plebiscite, interference with the work of electoral or referendum commissions, breach of secrecy of the ballot, miscounting of votes or incorrect summing up of vote returns, vote buying and bribery, participation with forged documents are all violations punished by the Criminal Code.[38] Courts in Georgia play a pivotal role in adjudicating election disputes. They review cases of alleged fraud and have the authority to annul election results in specific precincts if violations are substantiated.

IV. Election fraud in the 2024 Parliamentary elections of Georgia: allegations and legal outcomes

Following October 26, parliamentary elections, domestic observer groups and opposition parties filed several legal complaints alleging serious electoral violations, primarily concerning the secrecy of the vote.[39]

Georgian Young Lawyers’ Association (GYLA) called for the annulment of results in all 2,263 electronic precincts, citing mass violations of vote secrecy. GYLA reported that cameras installed in polling stations captured sensitive areas, like voting booths and registration desks.   One of the grave violation allegations concerned ballots, which were too thin, revealing voters’ choices through marker tracers when placing them in the electronic polling box. GYLA and other observers alleged that observers appointed by the CEC could distinguish which candidate the voter had chosen when assisting them with the electronic machine, compromising vote secrecy, which is a right guaranteed by the constitution. My Vote (a coalition of civil society organizations) filed complaints in 29 districts seeking annulment in 246 precincts (covering over 417,000 voters) due to the same violations.[40]

Judge Vladimer Khuchua of Tetritskaro Court became the only judge to uphold GYLA's claim, confirming that ballot secrecy was violated and annulling results in 30 precincts. However, the Tbilisi Court of Appeals later overturned this ruling.[41] The Kutaisi Court of Appeal dismissed GYLA's consolidated complaints for western Georgia and the Tbilisi City Court and Court of Appeal rejected all 11 lawsuits from opposition parties and CSOs challenging district commission protocols, calling them “groundless.”[42]

The CEC briefing about the completed process of consideration of appeals revealed that only 167 of 1201 complaints were partially or fully satisfied, while the remaining amount was not considered at all.[43] 

GYLA submitted a complaint concerning the massive violation of the secrecy of the ballot to the European Court of Human Rights, who has officially registered the case. GYLA alleges that Article 3 of Protocol No.1 to the ECHR has been violated.[44] As mentioned before, Article 3 upholds the rule of holding elections with secret ballots, ensuring the free expression of the opinion of the people.[45]

The complaint claims that the election administration failed to uphold its obligations, resulting in violation of the fundamental principle of secrecy of the ballot, also stating that the right to review election disputes through effective mechanisms was violated during the review of election disputes. Georgian legislation limits citizens' ability to file a complaint about an election dispute.  GYLA argues that this limitation does not comply with the Convention’s standards.[46] 

V. Reality check: distinguishing political claims from evidence-based findings

A.    OSCE/ODIHR Findings

The OSCE Office for Democratic Institutions and Human Rights (ODIHR) published its final report on Georgia's parliamentary elections. The report evaluates the elections' adherence to democratic standards and offers recommendations for improvement, however, it should be underlined that the OSCE/ODIHR observation mission does not determine the recognition or non-recognition of election results. It is merely an assessment to determine whether the electoral process complies with OSCE commitments and other international obligations regarding democratic elections.[47] 

OSCE Declared that the elections occurred amid significant political polarization and public dissatisfaction, particularly concerning recent legislative changes, which affected fundamental freedoms and civil society operations.​[48]

While Georgia's legal framework provides a basis for democratic elections, the legislation has undergone over 20 amendments since 2020, which produced inconsistencies and raised concerns about potential misuse for political advantage – so-called “political manipulation”.[49]

Based on OSCE/ODIHR findings, the election administration was well-prepared with extensive voter education on new voting technologies.[50] However, with various reports of pressuring the voters, especially the employees of public sector and economically vulnerable groups. The report also mentions cases of extensive tracking of votes on election day and raises concern about the voters' ability to cast ballots freely and without fear.[51]

While procedurally well-organized, election day was marked by tension accompanied with frequent compromises in vote secrecy, procedural inconsistencies, and reports of voter intimidation, negatively impacting public trust in the process. OSCE’s report highlighted issues of “widespread indications of pressure on voters, numerous reports of voters feeling pressured, voter tracking primarily by ruling party structures and affiliates, overcrowding at many polling stations, and frequent breaches of vote secrecy. Additionally, several incidents of physical altercations and intimidation occurred.”[52]

The report also detailed irregularities of campaign finance and media environment, declaring that the opposition was often put at a disadvantage regarding these issues.[53]

As one of the conclusions, the report presented: "Overall, the lack of a thorough review of election-day complaints and appeals by election commissions and courts, the dismissal of appeals on technical grounds or for insufficient substantiation, and the unduly short deadlines for filing appeals collectively undermined the right to due process and an effective remedy.”[54] Furthermore, insufficient response from authorities to concerns over electoral integrity not only failed to restore public trust but also deepened political polarization and escalated the ongoing crisis.[55]

B.     Allegations of violations of International and Domestic Law

Article 21 of the Universal Declaration of Human Rights establishes: “The will of the people shall be the basis of the authority of government; this will shall be expressed in periodic and genuine elections which shall be by universal and equal suffrage and shall be held by secret vote or by equivalent free voting procedures.”[56] These exact principles are also echoed in article 25 of the ICCPR, which is legally binding to the party states.[57] 

The principle of universal suffrage was allegedly violated as not all citizens could attend elections. As ISFED reports, right before October 26, identification cards were withdrawn from voters, depriving them of the opportunity to vote.  The citizens of Georgia that were outside the country were unable to vote due to insufficient precincts in foreign countries and queues outside the voting stations.[58] ISFED argued that the principle of genuine elections and free voting procedures were violated due to pressure, intimidation, and the control of voter’s will. In 31% of precincts, the observers identified the documentation of voters from coordinators appointed by the ruling party outside of the precincts. They collected personal information of voters and documented who they voted for. In 13% of precincts, observers also noticed instances of vote bribery. [59]

ISFED reported violations of equal suffrage through incidents of repeated voting. in 9% of precincts there were problems with the marking procedure, being handed more than one ballot, ballot-stuffing or attempts to vote on behalf of someone else. [60]Finally, there were alleged violations of vote secrecy: leaks from the marker making it able to identify who the person voted for, inappropriate placing of surveillance cameras, instances of members of the commission placing the ballot inside the machine instead of the voter, taking photos of the ballot or more than one person in the voting booths, all compromising secrecy of the vote.[61] 

In conclusion, all these incidents noticed and reported by observers can serve as evidence to allege violations of Article 25 of the ICCPR and Article 3 of Protocol 1 of the ECHR, as well as articles 164, 164 (1), 164 (2), 164 (3), 164(4) of the Criminal Code of Georgia.

VI. Conclusion

The 2024 parliamentary elections in Georgia marked a critical juncture for the country’s democratic development. Although Georgia has made constitutional commitments to European integration and democratic governance, the conduct and aftermath of these elections revealed alarming shortcomings in upholding the principles of electoral integrity. Allegations of voter intimidation, ballot secrecy violations, procedural irregularities, and the failure of domestic legal mechanisms to provide effective remedies have seriously undermined public trust in the electoral process. This has intensified domestic political polarization while casting doubt on the country’s readiness for deeper integration with European institutions.

Ultimately, the 2024 elections represent more than a political contest, they reflect the current state of Georgian democracy.

[1] Tamar Khuntsaria, 'Georgia’s Fight for Freedom: A Defining Moment for the West' (European Democracy Hub, 6 February 2025) <https://europeandemocracyhub.epd.eu/georgias-fight-for-freedom-a-defining-moment-for-the-west/> accessed 6 March 2025.

[2] ​Natia Mestvirishvili and Maia Mestvirishvili, '‘I am Georgian and therefore I am European:’ Re-searching the Europeanness of Georgia' (2014) 8(1) Central European Journal of International and Security Studies <https://cejiss.org/i-am-georgian-and-therefore-i-am-european-re-searching-the-europeanness-of-georgia> accessed 6 March 2025.

[3] Constitution of Georgia 1995, art 78.​

[4] Tamar Khuntsaria, 'Georgia’s Fight for Freedom: A Defining Moment for the West' (European Democracy Hub, 6 February 2025) <https://europeandemocracyhub.epd.eu/georgias-fight-for-freedom-a-defining-moment-for-the-west/> accessed 6 March 2025.

[5] Marc Goedemans, 'What Georgia’s Foreign Agent Law Means for Its Democracy' (Council on Foreign Relations, 21 August 2024) <https://www.cfr.org/in-brief/what-georgias-foreign-agent-law-means-its-democracy> accessed 6 March 2025.​

[6] ibid.

[7] Rayhan Demytrie and Emily Atkinson, 'Georgia Approves Controversial 'Foreign Agent' Law, Sparking More Protests' (BBC News, 14 May 2024) <https://www.bbc.com/news/world-europe-69007465> accessed 6 March 2025.​

[8] Jacqueline Howard, 'Georgia's Parliament Passes 'Foreign Agents' Bill Amid Mass Protests' (BBC News, 11 May 2024) <https://www.bbc.com/news/world-europe-69001339> accessed 6 March 2025.

[9] Rayhan Demytrie and Emily Atkinson, 'Georgia Approves Controversial 'Foreign Agent' Law, Sparking More Protests' (BBC News, 14 May 2024) <https://www.bbc.com/news/world-europe-69007465> accessed 6 March 2025.

[10] Tamta Kakhaberidze, 'More than 2,060,400 Voters Participated in the Elections' (Netgazeti, 26 October 2024) <https://netgazeti.ge/news/748557/> accessed 6 March 2025.

[11] ISFED, 'Summary Statement of the Election Day Observation of the 26 October 2024 Parliamentary Elections in Georgia' (ISFED, 26 October 2024) <https://isfed.ge/geo/2024-saparlamento/saqartvelos-parlamentis-2024-tslis-26-oqtombris-archevnebis-dghis-dakvirvebis-shemadjamebeli-gantskhadeba> accessed 6 March 2025.

[12] 'Edison Research Exit Poll Results Announced' (Publika, 26 October 2024) <https://publika.ge/edison-research-is-egzitpolis-shedegebi-cnobilia/> accessed 6 March 2025.

[13] Central Election Commission of Georgia, '2024 Parliamentary Election Results' (CEC, 26 October 2024) <https://results.cec.gov.ge/#/ka-ge/election_57/tr/dashboard> accessed 6 March 2025.

[14] 'Edison Research: 13-Percentage Point Difference Between Exit Polls and Official Election Results Suggests Vote Manipulation' (Civil.ge, 1 November 2024) <https://civil.ge/archives/633142> accessed 6 March 2025.​

[15] ISFED, 'Summary Statement of the Election Day Observation of the 26 October 2024 Parliamentary Elections in Georgia' (ISFED, 26 October 2024) <https://isfed.ge/geo/2024-saparlamento/saqartvelos-parlamentis-2024-tslis-26-oqtombris-archevnebis-dghis-dakvirvebis-shemadjamebeli-gantskhadeba> accessed 6 March 2025.

[16] 'Coalition for Change Presents Evidence of Alleged Election Fraud Scheme' (Civil.ge, 14 November 2024) <https://civil.ge/archives/635402> accessed 6 March 2025.​

[17] Human Rights Watch, Undue Punishment: Abuses against Prisoners in Georgia: Georgia’s International Obligations (2006) <https://www.hrw.org/reports/2006/georgia0906/4.htm> accessed 6 March 2025.

[18] International Covenant on Civil and Political Rights (adopted 16 December 1966, entered into force 23 March 1976) 999 UNTS 171, art 25.

[19] ibid, art 25 (b).

[20] UN Human Rights Committee, 'General Comment No. 25: The Right to Participate in Public Affairs, Voting Rights and the Right to Equal Access to Public Service (Art. 25)' (12 July 1996) UN Doc CCPR/C/21/Rev.1/Add.7.​

[21] ibid.

[22] Protocol No. 1 to the Convention for the Protection of Human Rights and Fundamental Freedoms (opened for signature 20 March 1952, entered into force 18 May 1954) 213 UNTS 262, art 3.

[23] ibid.

[24] European Observation and Democratic Support, Compendium of International Standards for Elections, 5th edn (EODS 2025) <https://www.eods.eu/compendium-of-international-standards-for-elections> accessed 13 March 2025.

[25] Document of the Copenhagen Meeting of the Conference on the Human Dimension of the CSCE (Organization for Security and Co-operation in Europe, 29 June 1990) <https://www.osce.org/odihr/elections/14304> accessed 13 March 2025.​

[26] OSCE Office for Democratic Institutions and Human Rights, Handbook for the Observation of Election Administration (OSCE 2023) <https://www.osce.org/odihr/elections/544240> accessed 13 March 2025.​

[27] ibid.

[28] OSCE Office for Democratic Institutions and Human Rights, Handbook for the Observation of Election Dispute Resolution (OSCE/ODIHR 2019) <https://www.osce.org/files/f/documents/9/7/429566_0.pdf> accessed 13 March 2025.

[29] ibid.

[30] ibid.

[31] Venice Commission, 'Report on Election Dispute Resolution' (8 October 2020) CDL-AD (2020)025 <https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL-AD(2020)025-e> accessed 13 March 2025.​

[32] Constitution of Georgia 1995, art 24.

[33] Election Code of Georgia 2011, art 1.

[34] Election Code of Georgia 2011, art 7.

[35] Election Code of Georgia 2011, art 7 (3).

[36] Election Code of Georgia 2011, para 10.

[37] Election Code of Georgia 2011, art 125.

[38] Criminal Code of Georgia 1999, art 162.

[39] Civil.ge, '2024 Election Live Blog: Georgia’s disputed elections’ (18 November 2024) <https://civil.ge/ka/archives/635456> accessed 20 March 2025.

[40] ibid.

[41] ibid.

[42] Radio Tavisupleba, 'Court Begins Reviewing Lawsuits on Summary Election Protocols’ (13 November 2024) <https://www.radiotavisupleba.ge/a/33200224.html> accessed 20 March 2025.​

[43] Civil.ge, '2024 Election Live Blog: Georgia’s disputed elections’ (18 November 2024) <https://civil.ge/ka/archives/635456> accessed 20 March 2025.

[44] GYLA.ge, 'European Court: Elections' ('ევროპული სასამართლო: არჩევნები', 20 March 2025) <https://gyla.ge/post/evropuli-sasamartlo-archevnebi> accessed 27 March 2025.

[45] Protocol No. 1 to the Convention for the Protection of Human Rights and Fundamental Freedoms (opened for signature 20 March 1952, entered into force 18 May 1954) 213 UNTS 262, art 3.

[46] GYLA.ge, 'European Court: Elections' ('ევროპული სასამართლო: არჩევნები', 20 March 2025) <https://gyla.ge/post/evropuli-sasamartlo-archevnebi> accessed 27 March 2025.

[47] ​Organization for Security and Co-operation in Europe, 'Georgia, Parliamentary Elections, 26 October 2024: Final Report' (20 December 2024) <https://www.osce.org/odihr/elections/georgia/584029> accessed 27 March 2025.​

[48] ibid, paragraph 3.

[49] ibid, para 4.

[50] ibid, para 5.

[51] ibid, para 15. 

[52] ibid.

[53] ibid, paragraph 10, 11. 

[54] ibid, para 16.

[55] ibid.

[56] Universal Declaration of Human Rights, art 21 (adopted 10 December 1948, UNGA Res 217 A(III), UN Doc A/810) <https://www.un.org/en/about-us/universal-declaration-of-human-rights>.

[57] International Covenant on Civil and Political Rights (adopted 16 December 1966, entered into force 23 March 1976) 999 UNTS 171, art 25 (b).

[58] International Society for Fair Elections and Democracy, 'Assessment of Elections: 2024 Parliamentary Elections in Georgia' (5 November 2024) <https://isfed.ge/eng/2024-saparlamento/archevnebis-shefaseba-2024-tslis-saqartvelos-parlamentis-archevnebi> accessed 29 March 2025.​

[59] ​ibid.

[60] ibid.

[61] ibid.