Columbia Global Freedom of Expression seeks to contribute to the development of an integrated and progressive jurisprudence and understanding on freedom of expression and information around the world. It maintains an extensive database of international case law. This is its newsletter dealing with recent developments in the field.
For a video to go viral on TikTok, the platform’s recommendation system may help distribute it widely. But what if in that video, someone is quite abundantly and explicitly insulting public officials? The recent ruling by the European Court of Human Rights (ECtHR) in Miladze v. Georgia takes up the matter. “Miladze demonstrates that Strasbourg is attentive not only to what is said but to how it is circulated and amplified through digital frameworks,” writes Natalie Alkiviadou, Senior Research Fellow at The Future of Free Speech, Vanderbilt University.
The case arose from transport reforms that expanded bus-only lanes, aiming to reduce car traffic in Tbilisi, Georgia. Irakli Miladze went on TikTok to criticize them. He was particularly upset that public officials enjoyed arbitrary exemption from the new rules. “If the transport policy is really so great, then why don’t you use buses yourselves?” Miladze addressed the authorities, Tbilisi’s mayor among them. Packed with vulgar and sexually explicit insults, the video received over 100,000 views and hundreds of shares. Miladze was fined. He then brought the case to the ECtHR.
The ECtHR found no violation of the right to freedom of expression under Article 10 of the European Convention on Human Rights. While underscoring the degrading nature of Miladze’s speech, the Court attached considerable importance to how TikTok spreads and amplifies content, makes it accessible to minors, and recommends videos through its algorithms. To Natalie Alkiviadou, an expert on hate speech and the ECtHR, “[t]his marks an incremental evolution in Article 10 jurisprudence, one that may reshape the boundaries of proportionality in the algorithmic age.”
In a new article published by CGFoE, Alkiviadou unpacks Miladze v. Georgia in the context of relevant ECtHR jurisprudence. She argues that the approach the Court applied to online political expression in the case risks weakening protection for the fundamental right to freedom of expression. Read the article on our website.
In a new article published by CGFoE, Natalie Alkiviadou argues that Miladze v. Georgia marks a significant development in the ECtHR’s approach to online political speech. “[T]his evolution introduces doctrinal uncertainty,” Alkiviadou writes. “If visibility, reach, or algorithmic amplification begin to operate as aggravating factors, there is a risk that expressive success itself may be indirectly associated with reduced protection under Article 10.”
Photo: Hawley Johnson, CGFoE Associate Director, and Natalie Alkiviadou, Senior Research Fellow, The Future of Free Speech, Vanderbilt University, at the launch of Alkiviadou’s Hate Speech and the European Court of Human Rights in October 2025.
Revisit the event on our YouTube channel.
European Court of Human Rights
Miladze v. Georgia
Decision Date: May 19, 2026
The European Court of Human Rights (ECtHR) held that imposing a fine on a Georgian social media user for publishing a TikTok video containing crude and offensive criticism of public officials did not violate Article 10 of the European Convention on Human Rights. The applicant posted the video to criticize what he viewed as the authorities’ failure to enforce traffic rules against government employees. While acknowledging that the video addressed a matter of public interest, the Court found that much of its content consisted of “violent verbal aggression” directed at the Mayor of Tbilisi that was “devoid of informational value” and therefore fell outside the scope of protected political criticism. The Court reiterated that offensive language is not always protected by Article 10, particularly where its purpose is “wanton denigration.” It further emphasized TikTok’s capacity for rapid and widespread dissemination, particularly among minors, and concluded that the modest administrative fine fell within the State’s margin of appreciation and was necessary in a democratic society to protect the rights of others.
Canada
Alford v. Canada
Decision Date: May 1, 2026
The Supreme Court of Canada ruled that Section 12 of the National Security and Intelligence Committee of Parliamentarians Act (NSICOP Act) is constitutionally valid. The case arose when Ryan Alford, a law professor, challenged statutory provisions that prohibit members of a national security oversight committee from claiming immunity based on Parliamentary Privilege, specifically freedom of speech in criminal proceedings related to the disclosure of protected information. The Court reasoned that Article 18 of the Constitution Act, 1867 grants Parliament the “plenary and continuing legislative power to define” [para. 20] its privileges, which includes the power to narrow or limit them as necessary to fulfill its constitutional role. It concluded that this specific limitation was a narrow, valid exercise of legislative power that did not fundamentally undermine the separation of powers or the essential functions of the legislature.
United Kingdom
Homer v. Information Commissioner
Decision Date: January 21, 2026
The First-tier Tribunal (General Regulatory Chamber) of the United Kingdom issued a decision ordering the Walsall Council to disclose a redacted version of a serious case review report. The case originated when Alex Homer, a journalist, requested access to a report detailing child sexual abuse, which the Council and the Information Commissioner refused to release in its entirety. The Court reasoned that a blanket approach to withholding the document was unlawful, as significant portions did not constitute sensitive personal data. It concluded that under the principles of transparency and the State’s obligations, the public interest in understanding safeguarding failures outweighed a total ban on disclosure.
The CGFoE Team and Ain Shams University students at the 2026 edition of the online seminar on Freedom of Expression in the Digital Realm
Another Milestone: CGFoE Wraps Up 4th Edition of Online Seminar on Freedom of Expression in the Digital Realm. The CGFoE team has recently concluded the 2026 edition of its flagship seminar, Freedom of Expression in the Digital Realm, delivered over the course of a month in collaboration with Ahmed Khalifa, Professor of Law at Ain Shams University and Coordinator of the MENA Rounds of the Price Media Law Moot Court Competition in Cairo, Egypt. Coordinated by CGFoE Legal Researcher and digital rights scholar Ibrahim Sabra, the seminar is designed to equip emerging freedom of expression scholars—student teams that qualified through the MENA Rounds—with a deeper understanding of the legal and policy challenges surrounding disinformation, hate speech, and generative AI.
● India: Live Tracking of Takedowns and Account Restrictions for Protest-Related Content. As youth-led protests continue in India, the Software Freedom Law Center (SFLC.in) is documenting reports of account restrictions, content takedowns, and reduced visibility impacting protest-related and political speech online. To determine the enforcement scale and patterns, support those affected, and call for transparency and accountability, SFLC.in’s Free Speech Tracker is covering the ongoing protest-related content moderation on a case-by-case basis.
● Lebanon: Israel’s Killing of Journalist Apparent War Crime. Human Rights Watch (HRW) and Amnesty International released the most comprehensive accounts to date of the killing of journalist Amal Khalil by the Israeli military on April 22, 2026. “Israeli forces’ continued killing of journalists shows a brazen willingness to commit atrocities without any fear of consequences,” said Ramzi Kaiss of HRW. The reports reconstruct Israel’s attack on al-Tiri, Lebanon, that left Khalil dead and her colleague Zainab Faraj severely injured. Both organizations conclude the attack must be investigated as a war crime and urge “the Lebanese government to accept the International Criminal Court jurisdiction over crimes committed on its territory since October 2023.”
● Mozambique: Court Nullifies Decree Allowing Government to Shut Down Internet. The Committee to Protect Journalists welcomes the recent judgment of Mozambique’s Constitutional Court upholding the right to access information. The Court struck down several provisions of the Telecommunications Traffic Control Regulations Decree that empowered the government to monitor communications, gather user data, suspend internet access, and “intervene technically in operators’ networks to enforce its decisions.” The ruling responded to the petition filed by the Centre for Democracy and Human Rights.
This Week in Protests
Last Thursday, August 6, across Costa Rica, thousands rallied in defense of judicial independence as President Laura Fernández’s government escalated attacks against the courts. On Saturday in Kut, Iraq, amid a nationwide electricity crisis, hundreds protested over chronic power cuts; security forces used tear gas. On Sunday in Athens, Greece, hundreds protested in solidarity with Palestine, demanding an end to Greek military and political cooperation with Israel. On Monday in Ranchi, Jharkhand, India, police used tear gas, water cannon, and baton charges on thousands of young people protesting exam-recruitment fraud, following the “Cockroach” movement that forced the education minister to resign—see CGFoE’s earlier analysis.
Find our web tool documenting protests since January 2026 here.
Last Thursday, thousands protested a controversial private property bill across Argentina. The police response in Buenos Aires left more than 1,500 people injured.
Background & Demands: The bill, framed by President Javier Milei’s government as a measure to attract investment, sought to streamline evictions, alter rural land-use rules, and make state acquisition of private property harder. One chapter would have lifted the foreign land purchase ceiling from 15% to 25%. Protesters carried banners reading, “The homeland is not for sale,” while opposition and environmental groups warned of “colonization, fragmentation, fracture, and balkanization of the homeland.”
Some results: Weeks of campaigning by trade unions, environmental organizations, Indigenous and peasant groups, and activists ultimately led to the withdrawal of changes to the law on foreign land purchase and to the Fire Management Law, which would have weakened protections for forests, wetlands, and grasslands affected by wildfires. Greenpeace described the outcome as “a victory for the people.” The protesters, however, demanded that the bill be rejected in its entirety.
Significance: This broad citizen mobilization has met one of the most violent and widespread repressions in recent years in Argentina.
State Response: On August 6, in Buenos Aires, as thousands rallied outside the Senate, where the bill was being debated, a joint federal and city operation of 820 officers applied Resolution 943/2023, the anti-picket protocol. The forces deployed tear gas, rubber bullets, and a water cannon after protesters threw stones—though that is disputed in light of reports about infiltrators inside the crowd. The Provincial Commission for Memory recorded 1,500 injuries among protesters. A press union recorded injuries to over 20 journalists who the security forces reportedly targeted. A photojournalist suffered a skull fracture. The police arrested 20 people. In the early hours of August 7, the Senate approved the cropped version of the bill.
FoE Violations: Attacks on journalists covering mass violations of the right to protest constitute an aggravated assault on the right to freedom of expression. The International Federation of Journalists condemned the repression and the authorities’ attempt to hinder protest coverage, calling for an independent investigation and expressing support for the complaint made by the Press Union of Buenos Aires and the Association of Graphic Reporters of the Argentine Republic.
Call for Applications for US Democracy Reporting Grants. The Pulitzer Center will award special grants for reporting projects on voting rights, civil and free speech rights, election transparency, and government accountability in the United States. Learn more here. Apply by August 31.
This newsletter is reproduced with the permission of Global Freedom of Expression. For an archive of previous newsletters, see here.