112 Towards the Effective Protection of LGBTI Persons Deprived of Liberty the police under the same pretense. The compelling positive obligation to provide protection implies that the officers ought to be aware of the risks arising from such public demonstrations, and to take appropriate measures to ensure the protection of those involved. In addition, the risk of violence should not be indiscriminately invoked as a way to prohibit peaceful demonstrations by a particular social group. Police officers’ failure to effectively protect LGBTI persons from violence and discrimination during peaceful demonstrations has a damaging impact not only on those directly involved in the marches, but also on the rights to freedom of peaceful assembly for all persons. As public demonstrations can entail risks for demonstrators, monitoring bodies – albeit a minority at the time of writing – may decide to be present during demonstrations for the purpose of monitoring police conduct. Case Law European Court of Human Rights, Identoba and Others v. Georgia (2015)83 In 2015, the European Court of Human Rights issued an important ruling about the police duty to protect LGBT individuals from targeted violence during peaceful demonstrations. The facts relate to a march organized in 2012 in Tbilisi, Georgia, to mark the International Day against Homophobia, which was violently disrupted by counter-demonstrators. The Court held that there had been a violation of the prohibition of inhuman and degrading treatment (Article 3) in conjunction with the prohibition of discrimination (Article 14), with respect to 13 applicants (represented by the NGO organizing the march – Identoba) who had participated in the peaceful demonstration. The Court found that, due to being “surrounded by an angry mob of people who outnumbered them, uttered serious threats and randomly used physical violence, the applicants must have felt fear and insecurity severe enough to reach the threshold to fall within the remit of Article 3 in conjunction with Article 14 of the Convention.” 83 See also M.C. and C.A. v. Romania, Application No. 12060/12, 2016.