On May 12, 2015, the European Court of Human Rights (the Court) ruled [3] in Identoba and Others v. Georgia that the failure of Georgian police to protect individuals taking part in a march against homophobia violated the European Convention on Human Rights [4].  According to the press release [5], approximately thirty people  who were taking part in the march were threatened and attacked by counter-demonstrators and that police at the scene, “when asked for help by the marchers, replied that they were not part of the police patrol and it was not their duty to intervene.”  The Court found there had been a violation of Article 3 (prohibition of inhuman or degrading treatment) taken in conjunction with Article 14 (prohibition of discrimination) and that there had been a violation of Article 11 (freedom of assembly and association) in conjunction with Article 14.  In particular, the Court noted “that the authorities knew or ought to have known of the risks surrounding the demonstration. They had therefore been under an obligation – but had failed – to provide adequate protection so that it could be held peacefully.”