Protection Against Counter-Demonstrations

### Positive Obligation: Protection

#Protection Against Counter-Demonstrations

1. **General Principles**:
- States have a positive obligation to protect lawful demonstrations from violent counter-demonstrations, including deploying police forces and taking preventive measures (6_74, 7_85, 7_86, 90_37).
- The Austrian legal system, for example, provides for criminal and administrative sanctions against those who disrupt assemblies and mechanisms for police protection (7_85, 7_86).
- The Court acknowledges that domestic authorities have wide discretion in choosing means to enable assemblies to take place without disturbance when there is a threat of violent counter-demonstrations. Authorities must evaluate the resources necessary to neutralize the threat rather than imposing a comprehensive ban on the assembly (113_33, 150_67).
- Participants in demonstrations must be able to hold their events without fearing physical violence from opponents, requiring the state to take proactive measures to protect demonstrators (234_22).

2. **Ensuring Peaceful Conduct of Assemblies**:
- **Adequate Police Presence**: Authorities dispatched a considerable number of police officers to ensure the peaceful conduct of assemblies when aware of planned events (300_28).
- **Insufficient Police Presence**: In some cases, the number of police officers dispatched was insufficient to prevent violence, indicating a failure to meet positive obligations (340_99, 340_100).

3. **Addressing Discrimination and Violence**:
- **Failure to Protect**: Authorities failed to meet their positive obligations when they did not take sufficient measures to protect demonstrators from violence (340_100, 383_218, 383_220).

4. **Specific Cases**:
- **LGBT March in Tbilisi**: Authorities failed to use the nine days of prior notice to prepare adequately for the LGBT march, resulting in insufficient police presence and a failure to meet positive obligations (340_99, 340_100).
- **IDAHO Event**: The police failed to conduct a proper evaluation of the resources needed to neutralize threats to LGBT demonstrators, indicating a failure to meet positive obligations (383_218, 383_219, 383_220).