Miladze v. Georgia, No. 41585/23, ECtHR (Fourth Section), 19 May 2026

The legitimacy and proportionality of the administrative sanction imposed for publishing a viral TikTok video containing crude and sexually explicit insults directed at public officials derive from the absence of satiric or rhetorical purposes, thereby constituting a form of wanton verbal aggression that exceeds the limits of political criticism.

Art. 10 ECHR

1. Freedom of expression constitutes one of the essential foundations of a democratic society and extends to information or ideas that offend, shock or disturb; however, the use of intentionally denigratory, vulgar, and sexually explicit expressions directed at public officials on social media platforms with high youth engagement does not enjoy the same protection where the primary intent is wanton insult rather than a debate on a matter of public interest.

2. There is no violation of art. 10 of the ECHR where the domestic judicial authorities have conducted a thorough and calibrated balancing exercise between the right to freedom of expression and the protection of the dignity and reputation of public officials, applying a minimum pecuniary sanction that is proportionate and devoid of any chilling or restrictive effects on the subsequent dissemination of the underlying political message.