Therefore, since March 2020, the Special Preventive Group has been closely monitoring the legal aspects of placing individuals in a special quarantine area, the conditions in quarantine areas, access to healthcare services and the general state of protection of the rights of quarantined persons. For this purpose, in March-May, a special preventive group carried out remote monitoring of quarantine areas and published a special report.482 5.2. Legal protection guarantees In the context of restriction of liberty, it is essential to provide legal safeguards against arbitrary restriction of liberty and ill-treatment. 5.2.1. Proportionality of the measure used and complaint mechanisms When using a quarantine measure restricting human liberty, all possible alternative, less restrictive measures to achieve the same goal should be considered.483 In the beginning of the pandemic, the Government of Georgia by the ordinance No164 of January 28, 2020 determined that all persons traveling from high-risk countries to Georgia or in contact with an infected person were automatically subject to 14 days of isolation (in quarantine spaces or self-isolation).484 From August 2020, the easing of mandatory isolation measures began in stages. The duration of isolation was reduced to 12 days, and initially citizens of 5 countries and then other countries were offered a PCR test as an alternative to mandatory isolation when entering Georgia, and then in every 72 hours for the next 12 days, testing at their own expense.485 This rule did not apply to Georgian citizens and 12-day mandatory isolation (placement in quarantine space) remained without alternative for them.486 The existence of restrictive regulations for Georgian citizens raised questions not only in terms of discrimination,487 but also in terms of proportionality.488 From October 21, 2020, 8-day self-isolation became mandatory for Georgian citizens instead of being placed in quarantine space,489 Later, 3-day self-isolation and PCR testing on the 3rd day performed at its own expense was determined as an alternative to 8-day self-isolation.490 The ombudsman's "Monitoring Report on Places of Detention Caused by Quarantine Measures Against New Coronavirus (COVID-19)" is available at: https://bit.ly/3do0zRr [last visited: 16.02.2021]. 483 Judgment of the European Court of Human Rights in Enhorn v. Sweden, no. 56529/00, para: 44. 484 Ordinance N164 of the Government of Georgia of January 28, 2020 on the Measures to Prevent the Possible Spread of New Coronavirus in Georgia and the Plan for Operative Response to Cases of New Coronavirus Disease. 485 Ordinance №495 of the Government of Georgia of August 12, 2020, available at: <https://bit.ly/3upP7Lg>, [Last visited: 25.02.2021]. 486 Self-isolation was permissible only in exceptional cases related to being under-age or health status.. 487 UN High Commissioner for Human Rights Arbitrary Detention Group N11 Conclusion - "Prevention of Arbitrary Restriction of Liberty during Emergency Public Health Measures" Paragraph 26 explicitly states that measures taken to prevent a pandemic should not be based on discriminatory based on citizenship. 488 The Public Defender of Georgia, in the opinion of friend of the amicus curiae appealed to the Tbilisi City Court regarding the lawsuit filed by a citizen Tornike Kublashvili and called on the court to discuss whether it is useful it is to impose lighter or stricter regulations only on the basis of citizenship. Available: https://bit.ly/2ZOPqRP [Last visited: 18.02.2021]. 489 Ordinance N637 of the Government of Georgia of October 21, 2020, available at: https://bit.ly/2ZVAGjX [Last visited: 23.02.2021]. 490 Resolution №40 of the Government of Georgia of January 29, 2021, available: https://bit.ly/3pUMA8k [Last visited: 23.02.2021]. 482 143