On November 12, 2025, Judge Giorgi Keratishvili of the Tbilisi Court of Appeals rejected the appeal filed by civil activist and member of the political party “Akhali” (New), Saba Skhvitaridze, and upheld the judgement issued on September 3, 2025, by Judge Jvjebе Nachkebia of the Tbilisi City Court. By that judgement, Saba Skhirtladze was found guilty under Article 120, Part 1 of the Criminal Code of Georgia (“intentional infliction of minor bodily harm”) and was sentenced to two (2) years of imprisonment.

Saba Skhvitaridze was convicted on the grounds that he allegedly struck a certain Mirian Kavtaradze twice on the head with a baton. It later turned out that Kavtaradze is a police officer who, on the night of the incident, was at the entrance of the “Courtyard Marriott” hotel located on Freedom Square in Tbilisi—wearing civilian clothes, masked, and apparently present to provoke the protesters. At the time, representatives of opposition parties were holding a meeting there, while Kavtaradze and other similarly disguised police officers were shouting obscenities at opposition representatives.

The judgement is unsubstantiated and unjust, as it relies on questionable evidence presented by the prosecution—including false testimonies by police officers and unauthenticated video footage of unclear origin. It completely disregards exculpatory evidence submitted by the defense, thereby contradicting the very principles of justice cited by the judge in the judgement.

The circumstances described below give rise to a well-founded suspicion that Saba Skhvitaridze—like dozens of other participants in civil protests—was punished for taking part in and helping to organize demonstrations against the regime.

We provided the public with a detailed analysis of the illegality of Saba Skhvitaridze’s prosecution on January 30, 2025.

This article does not evaluate the judgment of the Tbilisi Appeals Court. Since the Tbilisi Appeals Court fully accepted the facts and legal assessments ‘established’ by the Tbilisi City Court, everything that is said regarding the court of first instance applies, mutatis mutandis, to the Tbilisi Appeals Court as well.

1. Who is Saba Skhvitaridze?

As already mentioned, Saba Skhvitaridze is a member of the opposition political party Akhali (“New”). Before joining the party, he worked for the non-governmental organization Group for Reforms and Research and was an active member of civil society. His organization has worked—and continues to work—on issues related to human rights, democratic reforms, and election monitoring.

Saba Skhvitaridze was actively involved in organizing and participating in protests against the so-called “Russian Law” and was also one of the organizers of these demonstrations. He maintained close communication with student movements and was a public figure who frequently and openly expressed his critical views about the Georgian Dream government’s policies.

He was first detained for his civic activism on November 19, 2024, during a protest on Melikishvili Avenue in Tbilisi. Together with other demonstrators, he was protesting the massive falsification of the October 26, 2025 parliamentary elections. During his arrest, the police used physical force against him, and the court later fined him GEL 2,500.

2. The Original and Revised Charges

(a) The Original Charge and Its Groundlessness

Initially, Saba Skhvitaridze was charged under Article 353¹, Paragraph 2 of the Criminal Code of Georgia, which provides for criminal liability for inflicting harm on a police officer in connection with the performance of his official duties. This is a particularly serious offense punishable by imprisonment for a term of seven (7) to eleven (11) years.

However, both by the alleged “victim” Mirian Kavtaradze’s own admission and through other evidence presented by the prosecution, it was unequivocally established—and was clear from the outset—that on the night of the incident, Mirian Kavtaradze was dressed in civilian clothes, wearing a hood and a face mask. Consequently, charging Saba Skhvitaridze under Article 353¹, Paragraph 2 of the Criminal Code was an act of clear arbitrariness by the Prosecutor’s Office. Under these circumstances, even if Skhvitaridze had in fact committed the act he was accused of—which, in itself, has not been proven—he neither knew nor could have known that the person in front of him was a police officer performing “official duties.”

(b) The Revision of the Original Charge

Indeed, more than seven months after the initial charge—when the case was already being heard in court—the Prosecutor’s Office itself altered the accusation, reclassifying Skhvitaridze’s alleged act as a less serious offense: “intentional infliction of minor injury to health.” It is evident that by initially formulating the charge as a particularly grave crime, the Prosecutor’s Office deliberately abused its discretionary authority to initiate criminal prosecution.

According to Article 16 of the Criminal Procedure Code, a prosecutor exercises discretionary powers when deciding whether to initiate or terminate criminal proceedings, guided by public interest. However, Article 12, Paragraph 4 of the same Code stipulates that an individual’s legitimate interests take precedence over the public interest in uncovering a crime and punishing the offender.

(c) The Practical Consequence of the Unfounded Original Charge

At the very least, one tangible result of the Prosecutor’s Office’s deliberate and unfounded aggravation of the charge was that the court, without any proper justification, accepted the prosecution’s motion and imposed pre-trial detention as a preventive measure against Skhvitaridze.

While it is true that courts in Georgia rarely reject prosecutors’ motions for detention—thereby disregarding both the fundamental principles of criminal procedure and the jurisprudence of the European Court of Human Rights, including in cases involving Georgia—it remains the case that in practice, courts almost never impose pre-trial detention for less serious offenses.

3. The Unsubstantiated Nature of the Judgement

(a) The Evidence Relied Upon by the Court

(i) False Testimonies of Police Officers

The court primarily based its judgment on the false testimonies of the so-called “victim”, Mirian Kavtaradze, and his colleagues — Mikheil Tsiklauri, Luka Jincharadze, and Mikheil Sujashvili. For the reasons explained below, the court had full grounds and was in fact obliged not to regard their testimonies as credible. Instead, however, the court made these very statements one of the main foundations of its guilty judgement.

• Word-for-word identity of the prosecution witnesses’ testimonies. As we have already noted in our earlier analysis, during the investigation stage these individuals gave the investigator word-for-word identical testimonies. Each of them stated that on the evening of December 4, they were in the vicinity of the “Tbilisi Marriott” hotel while a protest was taking place in front of Parliament on Rustaveli Avenue. All of them claimed that they were “maintaining public order,” though they were dressed in civilian clothes.

Each of them also stated that the demonstrators were “aggressive,” “shouting and swearing” at police officers; that the plain-clothed “law enforcement officers” were calling on the protesters to remain calm; and that, according to their accounts, this allegedly made the protesters even more irritated. All the witnesses stated that they saw “one of the protesters, a young man of about 30, with a dark beard and a slightly aquiline nose, approach our colleague Mirian Kavtaradze and strike him twice in the head with an object resembling a baton, causing blood to flow from his head. After that, the mentioned person quickly disappeared into the crowd of demonstrators.” This phrase — like everything else in these so-called “witness” interrogation reports — was copied verbatim from one statement to another.

Such not only substantive but verbal identity of the testimonies indicates that, in reality, these statements were not the actual accounts of the alleged victim and his colleagues, but rather a version pre-written by the investigator, to which the “victim” and “witnesses” merely affixed their signatures. This circumstance would raise a reasonable doubt for any neutral and objective observer regarding the reliability of these “witnesses” and their testimonies. However, the court neither raised any questions on this matter nor made any mention of it in its judgement.

• Contradictory Testimonies Regarding the “Crime Scene.” It is particularly noteworthy that during the investigation, both the alleged victim and the other police witnesses identified the “crime scene” as the area near the Tbilisi Marriott Hotel on Rustaveli Avenue in Tbilisi. According to their statements, a protest rally was taking place there, where demonstrators were allegedly behaving “aggressively,” “shouting and swearing” at the plainclothes “law enforcement officers” for some reason. However, in their testimonies before the court, they changed their statements and now indicated a different location — the Courtyard Marriott Hotel on Freedom Square — as the scene of the incident, which is indeed where Saba Skhvitaridze was present. The distance between these two hotels is approximately 650 meters.

During the trial, the defense drew the court’s attention to this contradiction in the testimonies and argued that such inconsistency regarding the crime scene undermines the credibility of the witnesses. Nevertheless, when addressing this issue, the court relied on the investigator’s explanation that it was supposedly just a “technical mistake,” which was later corrected.[1]

The court’s disregard of this very serious issue, in favor of the prosecution, clearly demonstrates its bias. Declaring the contradictory testimonies about the crime scene to be a mere “technical mistake” is unconvincing for the following reasons:

• As already noted, the two hotels are 650 meters apart — the first, Tbilisi Marriott, is located on Rustaveli Avenue, while the second, Courtyard Marriott, stands on Freedom Square. In the original testimonies, not only the name “Tbilisi Marriott” was mentioned, but also its location — Rustaveli Avenue. Had this not been so, one might have thought that, since both hotels belong to the “Marriott” brand, such an error could indeed have been technical. However, those who gave false testimonies linked their fabricated narrative specifically to Rustaveli Avenue, as evidenced by the following circumstances.
• It should also be noted that this so-called “technical mistake” did not appear merely in one isolated document — it is repeated consistently across all procedural records prepared during the early stages of the investigation: in the witness interview protocols, in the identification protocols of Skhvitaridze, in the prosecutor’s decrees recognizing Skhvitaridze as an accused and Kavtaradze as a victim, in the court ruling on the application of a preventive measure, and elsewhere.
• In fact, the protest that evening — and during those days in general — was taking place specifically on Rustaveli Avenue, in front of the Parliament building, not at Freedom Square. This is why, in their initial testimonies, the false witnesses claimed that they were “maintaining public order” at the protest and that the demonstrators were “behaving aggressively” toward them. Accordingly, from the very beginning, they constructed a completely fabricated narrative about where and under what circumstances the alleged “crime” occurred.
• Such a false narrative was deliberately invented because, at that time and moment when the alleged “victim” sustained the injury, he and his colleagues were not maintaining order at the protest. Instead, they had been sent as provocateurs and “Titushkis” to the Courtyard Marriott Hotel on Freedom Square, with the purpose of inciting a confrontation with the representatives of opposition parties gathered there. As it turned out, this objective was indeed achieved, because an actual clash occurred between the police “Titushkis” and opposition party representatives. The incident began when Kavtaradze struck one of the opposition women who had removed his hood. It appears that it was precisely as a result of this clash that the “victim” police officer sustained his injury. However, such conduct by a police officer — provoking a fight and then participating in it — not only falls outside the scope of his official duties but is essentially criminal. Any impartial court would have classified it as such.
• It was to conceal and cover up this criminal behavior that the investigator fabricated the narrative that the alleged victim and other “witnesses” were supposedly maintaining public order at the protest on Rustaveli Avenue. Freedom Square and the Courtyard Marriott would not have worked for this false narrative because no protest was taking place there that evening. Later, when it became clear that the location, circumstances, and course of the fight had been broadcast live by television companies and witnessed by numerous other observers, the prosecution was forced to clarify the charges and change the stated location of the incident.
• Following the revision of the charge and the crime scene, the prosecution also devised a new purpose for the presence of the “victim” and his accomplices at the scene. In the amended charge and testimonies, it was stated that the police “Titushkis” were not there to “maintain public order” but were allegedly carrying out an “operational” or secret assignment, and therefore were not wearing police uniforms[2] — a claim the court accepted as credible.[3]

Based on the above, by accepting the “technical mistake” explanation, the court turned a blind eye to the fundamental contradictions between the prosecution’s versions and the false testimonies of the police witnesses. In doing so, it legitimized what, for an objective and impartial court, would have provided grounds to reject the prosecution’s evidence and acquit the defendant.

(ii) False Testimony of the Case Investigator

The court also based its judgement on the testimony of the investigator, Salome Edisherashvili.[4]  This is one of the main figures in this case, a person who deliberately falsified the case — a perjurer, someone who, in addition to creating a false narrative for the case, assigned each participant a role she invented, which was reflected in the false testimony of witnesses, police statements, and other procedural documents. Furthermore, according to Saba Sukhitaridze, Edisherashvili left him alone in his room with several masked individuals who brutally attacked Sukhitaridze.

(iii) Unlawful Identification Protocols

The court also relied on the identification protocols, according to which the false police witnesses “identified” Saba Skhvitaridze from a photograph as the person who allegedly struck the “victim” police officer twice with a baton on the evening of December 4, near the Tbilisi Marriott Hotel.[5]

According to Article 131, Paragraph 3 of the Criminal Procedure Code (CPC), when conducting an identification procedure, the person to be identified must be presented alongside at least two individuals of the same gender who do not significantly differ in appearance or clothing. Paragraph 5 of the same article stipulates that identification by photograph may be conducted only when presenting the person in person is impossible or would require unreasonable effort.

According to the case materials, in this instance, the two false police witnesses were shown photographs for identification on December 5, 2025, at 02:15 and 02:40, whereas Saba Skhvitaridze was brought to the Tbilisi Police Department at 04:52. Actually, he had been detained near Zestafoni, about 200 km from Tbilisi, which, according to the testimony of Skhvitaridze’s father, occurred at approximately 00:30.[6]

From these facts, it is clear that presenting Saba Skhvitaridze in person for identification was entirely possible, did not require unreasonable effort, and in fact, he was brought to the Tbilisi Police Department later that same night. Therefore, the investigator was obligated to wait for Skhvitaridze’s arrival at the police station and conduct the identification procedure in his presence. Instead, she did not wait and carried out the identification using photographs, grossly violating Article 131, Paragraph 5 of the CPC.

According to Article 72, Paragraph 1 of the CPC, evidence obtained in violation of procedural rules, and any other evidence obtained as a result that worsens the legal position of the accused, is inadmissible and has no legal effect. Paragraph 6 of the same article stipulates that inadmissible evidence cannot form the basis of a court decision.

Since, in this case, the identification of Saba Skhvitaridze was conducted in substantial violation of Article 131, Paragraph 5 of the CPC, the court was obliged to recognize the identification protocols as inadmissible evidence. Instead, the court not only failed to do so but also relied on them as one of the main bases for its guilty judgement.

(iv) Video Record which Should be Considered Inadmissible Evidence

One of the main pieces of evidence the court relied on for the guilty judgement was a video recording, which, according to the prosecution and now the court, “clearly shows the face of Saba Skhvitaridze holding an object resembling a baton” and “also clearly shows Mirian Kavtaradze being struck several times in the head by Saba Skhvitaridze with the baton-like object.”[7]

The court rejected the defense’s plea that: (a) the person recorded in the video is not Saba Skhvitaridze, and (b) the video itself was obtained in violation of procedural rules, its authenticity had not been verified, and it was not determined whether it had been edited. The court ruled that in the episode of the confrontation, Saba Skhvitaridze was “unequivocally identified” and that “no scientific knowledge or habitoscopic expertise was necessary” to establish his identity.[8] Regarding the authenticity of the video, the court stated that the investigator questioned as a witness the person who “obtained” the video, Alexander Gachechiladze, and that the investigator, Salome Edisherashvili, who requested and reviewed the video, was questioned in court. Based on this, the court concluded that “the authenticity of the video is not in doubt either.”[9]

Due to the circumstances described below, this video recording, instead of serving as a basis for a guilty judgement, should have been considered inadmissible evidence by the court.

 (iv-a) Absence of a Habitoscopic Expert Report

Concerning the first issue raised by the defense, the court’s claim that Saba Skhvitaridze’s face is clearly visible in the video and that no scientific knowledge or habitoscopic expertise was required is illegal and arbitrary.

Firstly, Saba Skhvitaridze’s face is not clearly visible. Secondly, since the defense raised the issue that the person holding the baton in the video might not be Saba Skhvitaridze, the court was indeed required to have objective evidence — in this case, a habitoscopic expert report, which would scientifically analyze facial features and conclusively determine that the person in the video, holding the baton and striking the alleged victim, is indeed Saba Skhvitaridze and no one else.

In the absence of such objective evidence, the court based its guilty judgement on its own subjective assessment and assumption, grossly violating one of the fundamental principles of the Criminal Procedure Code (CPC), which prohibits convicting someone based on mere assumption (Article 269, Paragraph 2 of the CPC). Furthermore, by doing so, the court flagrantly violated the principles of adversarial trial and equality of arms, enshrined in Article 9 of the CPC. The court effectively “corrected” the prosecution’s deficiency — the absence of a habitoscopic expert report — through its subjective judgment, thereby abandoning its role as a neutral judge and assuming the role of the accuser.

The habitoscopic examination should also have addressed the authenticity of the video itself, including whether there were signs of editing, a matter which will be discussed in more detail below.

(iv-b) Origin and Authenticity of the Video Recording Not Established

According to the first paragraph of Article 78 of the Criminal Procedure Code (CPC), a document has evidentiary value at the request of a party if its origin is known and it is authentic. A document or physical evidence is admissible if a party can summon as a witness the person who obtained/created it and/or with whom it was kept before being presented to the court.

According to the case materials, the video recording that served as the basis for Saba Skhvitaridze’s conviction was viewed by investigator Salome Edisherashvili on December 5, 2025, on the Facebook page of a certain Tato Maisuradze, and it was downloaded from that page. The relevant inspection report also indicates the web address of Tato Maisuradze’s Facebook account. Accordingly, the court’s assertion that the “authenticity of the video recording is not in doubt merely because Salome Edisherashvili was questioned in court, and another police officer, who had kept a copy of the video downloaded from Facebook, was questioned during the investigative stage,” is insufficient for the purposes of the first paragraph of Article 78 of the CPC.

First and foremost, attention must be paid to the provision of the first paragraph of Article 78 of the CPC, which states that a document has evidentiary value if two conditions are met: (a) its origin is known; and (b) it is authentic.

• The Problem of Origin

Salome Edisherashvili could provide the court with only partial (and not complete) testimony regarding the origin of the video recording. It was partial because Salome Edisherashvili was not the original source of the video and did not create it. Accordingly, in order for the court to have a complete understanding of the origin of the video, first, Tato Maisuradze – the person who uploaded the video to their Facebook page and from whom Salome Edisherashvili downloaded it – should have been questioned as a witness in court. Second, it is possible that Tato Maisuradze was also not the creator of the video and had obtained it from someone else. Again, this circumstance should have been clarified based on questioning Tato Maisuradze, and if another person existed, they should also have been questioned.

However, besides Salome Edisherashvili, no one else was questioned in court regarding the origin of the video. Consequently, the origin of the video cannot be considered established, and the court openly violated the law – the requirement of the first paragraph of Article 78 of the CPC.

• The Problem of Authenticity

Even if the origin of the video recording had been fully established—which, as already noted, is not the case—the issue of its authenticity remains completely unresolved. The court erred, or deliberately misled the public, when it stated that the issue of authenticity is not in question merely because investigator Salome Edisherashvili was questioned in court. As already mentioned, the first paragraph of Article 78 of the CPC requires that both the origin and the authenticity of the document be established.

The court could not determine the authenticity of the video solely based on the questioning of Salome Edisherashvili or any other person who obtained or stored the document, because such matters are determined by an expert examination—in this case, a habitoscopic examination. According to judicial practice, it is precisely the habitoscopic examination that should determine whether the video recording is genuine, whether it was artificially created, or whether there are traces of editing. However, as already noted, no habitoscopic expert opinion was obtained, and the court did not even discuss these issues because it lacks the relevant scientific knowledge and could not make any assessment, not even at the level of assumption.

Consequently, since the origin of the video recording was not fully established and its authenticity was not determined at all, the court should have recognized this video as inadmissible evidence. Instead, the court used this inadmissible evidence as the basis for a conviction, thereby once again grossly violating the requirement of the first paragraph of Article 72 of the CPC.

(b) Evidence disregarded by the court

During both the investigation and the court proceedings, the defense presented numerous witness statements that excluded Saba Skhvitaridze’s commission of the crime of which he was accused.[10]

Regarding this evidence, the court limited itself to a brief statement:

"These witnesses do not provide direct information regarding the infliction of harm on Mirian Kavtaradze by Saba Skhvitaridze. Therefore, the court will not give additional attention to their testimonies."[11]

Thus, the court simply refused to assess the defense’s evidence. Apparently, for the court, evidence only has evidentiary value when it is incriminating to the accused and not exonerating. Such an approach fundamentally contradicts the universal principles of a fair trial and the requirements of the first paragraph of Article 13 and the second paragraph of Article 82 of the CPC, which state that no evidence has pre-determined value.

(c) The court’s hollow statements on the principles of a fair trial

According to paragraph 7 of Article 31 of the Constitution of Georgia, a conviction must be based on irrefutable evidence. Any doubt that cannot be confirmed in accordance with the legally established procedure must be resolved in favor of the accused.

This fundamental principle of a fair trial is also reflected in the Criminal Procedure Code. According to paragraph 2 of Article 13 of the CPC, a conviction must be based solely on a combination of coherent, clear, and convincing evidence that establishes the person’s guilt beyond a reasonable doubt.

According to paragraph 3 of Article 82 of the same code, a person can be found guilty only on the basis of a combination of coherent evidence that establishes guilt beyond a reasonable doubt.

According to paragraph 3 of Article 5 of the same code, any doubt arising during the assessment of evidence that is not confirmed in accordance with the legally established procedure must be resolved in favor of the accused (defendant).

The court is well aware of these fundamental principles of criminal procedure. It even references them in its judgement.[12] To reinforce these principles, the court abundantly cites relevant decisions of the European Court of Human Rights and the Constitutional Court of Georgia.[13]

The circumstances described above confirm that the court’s judgement was issued in gross violation of these principles, and that the court’s references to them are merely formalistic.

(d) Lack of response to allegations of torture

As noted in our previous analysis and above, after being taken to the police, Saba Skhvitaridze was brutally beaten by masked individuals, whom investigator Salome Edisherashvili left alone with him in her office.

In discussing this issue, the court limited itself to a brief comment:

"Following the defense’s statement, the Special Investigative Service initiated an investigation. At the time of the judgement, the investigative body had not issued a final decision. Therefore, the court lacks the legal authority, within the framework of this criminal case, to consider the defendant’s claims against law enforcement officers as established or unfounded, as this requires additional investigation, and issuing a final decision falls within the competence of the investigative body."[14]

In response to such a dismissive attitude by the judge toward alleged torture or other forms of ill-treatment, it must be noted that over the past 10 months, the investigation has not advanced a single step. Moreover, the Special Investigative Service, whose potential final decision the court refers to, has already been abolished, and its cases have been transferred to the same Prosecutor’s Office that brought the false charges against Saba Skhvitaridze.

Conclusion

• The case of Saba Skhvitaridze represents an example of legal and political persecution by the “Georgian Dream” regime against a civic activist. On September 3, 2025, the Tbilisi City Court found Skhvitaridze guilty of intentionally causing minor bodily harm and sentenced him to two years of imprisonment. The judgement is unfounded and is based on false testimonies and dubious video material. Skhvitaridze has been known as a member of the political party “New” and as a civic activist who actively participated in anti-government and anti-Russian demonstrations.
• During the proceedings, the prosecution initially charged Skhvitaridze with a serious crime — harming a police officer’s health during the performance of official duties, which carries a sentence of 7–11 years of imprisonment which, in our assessment, is an example of the prosecution’s abuse of the criminal justice process. Later, the charge was downgraded to a lesser offense, but the later charge was as arbitrary and unlawful as the original one.
• The court failed to uphold the fundamental principles of a fair trial — the presumption of innocence, impartial assessment of evidence, and the rule to decide in favor of the accused in case of doubt. Additionally, information regarding physical violence against Skhvitaridze by the police was ignored.
• The court based its judgement on police officers’ identical and mutually contradictory testimonies, a photo-based identification, and a video taken from social media, whose origin and authenticity were not verified. The person depicted in the video is not Saba Skhvitaridze and that the court relied on inadmissible evidence. Furthermore, the testimonies of defense witnesses, which confirmed Skhvitaridze’s innocence, were disregarded.
• The case is perceived as political retaliation against an opposition activist and reflects systemic problems within Georgia’s justice system. The extent of falsehood allowed by the police, the prosecution, and the court in this case indicates that Saba Skhvitaridze is a prisoner of conscience.

Public officials who participated in the falsification of Saba Skhvitaridze’s case and/or in his ill-treatment:

Judges
 Jvabe Nachkebia
 Lela Maridashvili

 Giorgi Keratishvili

Prosecutor
 Roin Khintibidze

Police officers
 Salome Edisherashvili
 Mirian Kavtaradze
 Mikheil Sujashvili
 Mikheil Tsiklauri
 Luka Jinchradze
 Vano Gavashelishvili
 Levan Kundukhashvili
 Tornike Japaridze
 Zurab Beruashvili
 Theodore Giorgashvili
 Giorgi Tabatadze
 Ekaterine Mtivlishvili
 Aleksandre Gachechiladze
 Ioseb Sigua
 Giorgi Taqadze
 Soso Odishvili

[1] Tbilisi City Court judgment of September 3, 2025, regarding Saba Shvitaridze, para. 3.20.

[2] Id., paras. 2.5-2.8.

[3] Id., para. 3.16.

[4] Id., paras. 2.10 and 3.18.

[5] Id., para. 3.16.

[6] Id., para. 2.22.

[7] Id., para. 3.18.

[8] Id., para. 3.18.

[9] Id., para. 3.18.

[10] Id., paras. 2.23-2.30.

[11] Id., para. 3.22.

[12] Id., paras. 3.1-3.3.

[13] Id., paras. 3.4-3.11.

[14] Id., para. 3.21.