CYIL vol. 13 (2022)

CYIL 13 ȍ2022Ȏ ARTICLE 18 OF THE ECHR AS AN EARLY WARNING INSTRUMENT FOR THREATS… Thus we see that the court has changed its policy in regard to the burden of proof while applying Article 18 in the Merabashvili v. Georgia case and started more actively referring to Article 18. The court showed that it is aware of the decline and crisis of democracy and rule of law in some member states. In this regard, there are two ways for member states. First, to take note on Court’s judgments in regard of Article 18 and correct shortcomings. Second, to deepen the crisis and follow Russian direction.

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