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  • 13. The handling of assemblies by law-enforcement agents


    1. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, paras. 37-49; UN Human Rights Council, First Thematic Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, UN Doc. A/HRC/20/27,21 May 2012, paras. 26-28; Praded v. Belarus, Human Rights Committee, Views of 29 November 2014, UN Doc. CCPR/C/112/D/2029/2011, para. 7.8.
    2. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 4.
    3. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 40.
    4. IACHR, Report on Citizen Security and Human Rights, OEA/Ser.L/V/II, Doc 57, 31 December 2009,para. 193.
    5. Novikova and Others v. Russia, ECtHR, Judgment of 26 April 2016, para 171; see also Oya Ataman v. Turkey, ECtHR, Judgment of 5 December 2006, para. 39.
    6. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 66.
    7. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 49.
    8. Gillan and Quinton v. the United Kingdom, ECtHR, Judgment of 12 January 2010, paras. 80-83.
    9. Gillan and Quinton v. the United Kingdom, ECtHR, Judgment of 12 January 2010, para. 85.
    10. See, for example, Djavit An v. Turkey, ECtHR, Judgment of 20 February 2003 (the applicant was prevented by Turkish and Turkish-Cypriot authorities from visiting the “buffer-zone” or the southern part of the island in order to participate in bi-communal meetings with Greek Cypriots); Schwabe and M.G. v. Germany, ECtHR, Judgment of 1 December 2011 (the applicants were detained on their way to a demonstration where the police feared terrorism or rioting, because they were carrying banners bearing the inscriptions “Freedom for all prisoners” and “Free all now” and held for almost six days in order to prevent them from inciting others to liberate prisoners); Huseynli and Others v. Azerbaijan, ECtHR, Judgment of 11 February 2016 (the applicants were arrested two days prior to a demonstration and rapidly sentenced to seven days’ administrative detention on arbitrary grounds, in order to prevent their participation in the demonstration and to punish them for having participated in opposition protests); Eğitim ve Bilim Emekçileri Sendikası v. Turkey, ECtHR, Judgment of 5 July 2016 (the applicants were stopped on a highway on their way to a demonstration for free and quality education and held there for several hours); Kasparov v. Russia, ECtHR, Judgment of 11 October 2016 (the applicant’s flight ticket was seized for “forensic examination”, preventing him from reaching an opposition rally).
    11. Kasparov v. Russia, ECtHR, Judgment of 11 October 2016, para. 66.
    12. Eğitim ve Bilim Emekçileri Sendikası v. Turkey, ECtHR, Judgment of 5 July 2016, paras. 106-109.
    13. Ziliberberg v. Moldova, ECtHR, Decision of 4 May 2004, para. 2; Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, para. 99; Primov and Others v. Russia, ECtHR, Judgment of 12 June 2014, para. 155.
    14. See UN Human Rights Council, Second Thematic Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, UN Doc. A/HRC/23/39, 24 April 2013, para. 70; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 46; AComHPR, Report of the Study Group on Freedom of Association and Assembly in Africa, 2014, p. 26, para. 24.
    15. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 61.
    16. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 154.
    17. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.3.
    18. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, para. 133.
    19. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 61.
    20. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, paras. 155-156.
    21. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.1; AComHPR, Report of the Study Group on Freedom of Association and Assembly in Africa, 2014, p. 65, para. 39.
    22. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.3.
    23. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 67.
    24. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 61.
    25. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.5.
    26. Primov and Others v. Russia, ECtHR, Judgment of 12 June 2014, para. 152.
    27. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 62.
    28. R.B. v. Hungary, ECtHR, Judgment of 12 April 2016, para. 99. See also Király and Dömötör v. Hungary, ECtHR, Judgment of 17 January 2017, para. 64.
    29. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 61.
    30. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 165.
    31. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 63; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.5.
    32. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 63; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.4; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 168.
    33. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 45; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 23.3; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 161.
    34. Servellón García et al. v. Honduras, IACtHR, Judgment of September 21, 2006, para. 93.
    35. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 13.
    36. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.2.
    37. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 10.
    38. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 81.
    39. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 60; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.6; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 82.
    40. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 168.
    41. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.7.
    42. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 5.
    43. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 38.
    44. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 39.
    45. IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 Doc. 5 Rev. 1, 7 March 2006, para. 68.
    46. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 13.1.
    47. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 13.2.
    48. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, paras. 149-150.
    49. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Guideline 5.4.
    50. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, para. 129.
    51. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, paras. 128-129.
    52. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, para. 118.
    53. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, paras. 126-128.
    54. Frumkin v. Russia, ECtHR, Judgment of 5 January 2016, paras. 129-130.
    55. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 42.
    56. İzci v. Turkey, ECtHR, Judgment of 23 July 2013, para. 99.
    57. Giuliani and Gaggio v. Italy, ECtHR, Grand Chamber Judgment of 24 March 2011, para. 250.
    58. Zambrano Vélez et al. v. Ecuador, IACtHR, Judgment of July 4, 2007 (Merits, Reparations and Costs), para. 87.
    59. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, paras. 38, 42, 49, 52, 55, 66 and 67.
    60. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 7.
    61. IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 Doc. 5 Rev. 1, 7 March 2006, para. 141.
    62. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, paras. 147-148.
    63. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principles 18-21.
    64. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 13.
    65. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 50.
    66. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 1; UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 51; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II, Doc. 66, 31 December 2011, para. 141; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, paras. 7-8; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Guideline 5.5 and Explanatory Notes, paras. 171-178.
    67. IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II, Doc. 66, 31 December 2011, para. 141. See also Zambrano Vélez et al. v. Ecuador, IACtHR, Judgment of July 4, 2007 (Merits, Reparations and Costs), para. 86.
    68. Giuliani and Gaggio v. Italy, ECtHR, Grand Chamber Judgment of 24 March 2011, para. 249.
    69. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 52.
    70. Şimşek and Others v. Turkey, ECtHR, Judgment of 26 July 2005, para. 106.
    71. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 37.
    72. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 2; UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, paras. 52-55; UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 14; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II, Doc. 66, 31 December 2011, para. 143; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 15; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Guideline 5.5 and Explanatory Notes, para. 172.
    73. Şimşek and Others v. Turkey, ECtHR, Judgment of 26 July 2005, paras. 110-112. See also Güleç v. Turkey, ECtHR, Judgment of 27 July 1998, para. 71: ”The gendarmes used a very powerful weapon because they apparently did not have truncheons, riot shields, water cannon, rubber bullets or tear gas. The lack of such equipment is all the more incomprehensible and unacceptable because the province of Şırnak, as the Government pointed out, is in a region in which a state of emergency has been declared, where at the material time disorder could have been expected.”
    74. UN Human Rights Council, Report of the UNSR on his mission to the Republic of Korea, A/HRC/32/36/ Add.2, para 31.
    75. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 14.2.
    76. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 57.
    77. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 4.
    78. Zambrano Vélez et al. v. Ecuador, IACtHR, Judgment of July 4, 2007 (Merits, Reparations and Costs), para. 83.
    79. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.1.2.
    80. See, for example, Pekaslan and Others v. Turkey, ECtHR, Judgment of 20 March 2012, para. 81; İzci v. Turkey, ECtHR, Judgment of 23 July 2013, para. 55.
    81. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.1.2.
    82. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 58.
    83. Landaeta Mejías Brothers et al. v. Venezuela, IACtHR, Judgment of August 27, 2014, para. 136.
    84. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, paras. 10 and 11.
    85. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 60.
    86. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.1.4.
    87. IACHR, Report on Citizen Security and Human Rights, OEA/Ser.L/V/II, Doc 57, 31 December 2009, para. 118.
    88. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 10.
    89. Giuliani and Gaggio v. Italy, ECtHR, Grand Chamber Judgment of 24 March 2011, para. 176.
    90. Giuliani and Gaggio v. Italy, ECtHR, Grand Chamber Judgment of 24 March 2011, para. 249.
    91. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 1.
    92. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 18.
    93. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 2; UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, paras. 52-55; UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 14; IACHR, Second Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II, Doc. 66, 31 December 2011, para. 143; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 15; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Guideline 5.5 and Explanatory Notes, para. 172.
    94. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 67(e).
    95. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 82.
    96. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 18; IACHR, Report on Citizen Security and Human Rights, OEA/Ser.L/V/II, Doc 57, 31 December 2009, para. 118; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 81; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.1.4.
    97. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 60; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 22.6; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 82.
    98. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 11(d).
    99. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 227.
    100. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 65.
    101. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 11(f); IACHR, Report on Citizen Security and Human Rights, OEA/Ser.L/V/II, Doc 57, 31 December 2009, para. 119; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 24.4.
    102. Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 2; UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 55; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.3.1; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 15; OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Guideline 5.5.
    103. UN Human Rights Council, Resolution 25/38 on the promotion and protection of human rights in the context of peaceful protests, UN Doc. A/HRC/RES/25/38, 11 April 2014, para. 15; Basic Principles on the Use of Force and Firearms by Law Enforcement Officials (adopted at the Eighth United Nations Congress on the Prevention of Crime and the Treatment of Offenders, Havana, 27 August to 7 September 1990), UN Doc. A/CONF.144/28/Rev.1 at 112, Principle 3; UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 55; AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 21.3.1; IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 84.
    104. Abdullah Yaşa and Others v. Turkey, ECtHR, Judgment of 16 July 2013, paras. 49-51. . See also Ataykaya v. Turkey, ECtHR, Judgment of 22 July 2014, para. 57.
    105. IACHR, Annual Report 2015, March 17, 2016, Chapter IV.A, para. 16.
    106. UN Human Rights Council, First Thematic Report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association, Maina Kiai, UN Doc. A/HRC/20/27, 21 May 2012, para. 35.
    107. See, among others, Ali Güneş v. Turkey, ECtHR, Judgment of 10 April 2012; Abdullah Yaşa and Others v. Turkey, ECtHR, Judgment of 16 July 2013; İzci v. Turkey, ECtHR, Judgment of 23 July 2013; Ataykaya v. Turkey, ECtHR, Judgment of 22 July 2014.
    108. Abdullah Yaşa and Others v. Turkey, ECtHR, Judgment of 16 July 2013, para. 43.
    109. Abdullah Yaşa and Others v. Turkey, ECtHR, Judgment of 16 July 2013, para. 48. See also Ataykaya v. Turkey, ECtHR, Judgment of 22 July 2014, para. 56.
    110. İzci v. Turkey, ECtHR, Judgment of 23 July 2013, para. 60.
    111. Ali Güneş v. Turkey, ECtHR, Judgment of 10 April 2012, para. 41.
    112. European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment, Report to the Government of Bosnia and Herzegovina on the Visit to Bosnia and Herzegovina Carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment from 19 March to 30 March 2007, CPT/Inf (2009) 25, 14 October 2009, para. 79.
    113. UN Human Rights Council, Joint report of the Special Rapporteur on the rights to freedom of peaceful assembly and of association and the Special Rapporteur on extrajudicial, summary or arbitrary executions on the proper management of assemblies, UN Doc. A/HRC/31/66, 4 February 2016, para. 65.
    114. AComHPR, Guidelines for the Policing of Assemblies by Law Enforcement Officials in Africa, 4 March 2017, para. 14.1.
    115. IACHR, Report on the Situation of Human Rights Defenders in the Americas, OEA/Ser.L/V/II.124 Doc. 5 Rev. 1, 7 March 2006, para. 68.
    116. OSCE-ODIHR and Venice Commission, Guidelines on Freedom of Peaceful Assembly, 2nd edn, 2010, Explanatory Notes, para. 153.
    117. Ataykaya v. Turkey, ECtHR, Judgment of 22 July 2014, paras. 52-54 (references omitted); see also Cestaro v. Italy, ECtHR, Judgment of 7 April 2015, para. 217.
    118. Ataykaya v. Turkey, ECtHR, Judgment of 22 July 2014, paras. 52-54 (references omitted).