On November 28, 2017, the European Court of Human Rights ruled in Merabishvili v. Georgia that Georgia had violated the rights of former Prime Minister of Georgia, Ivane Merabishvili, by holding him in pre-trial detention that was initially justified, but later deemed to be a means of exerting pressure on him in order to obtain information. Merabishvili argued “that the arrest and the pre-trial detention had aimed to remove him from the political scene, and that the Chief Public Prosecutor . . . had attempted to use his detention as leverage to pressure him to provide information about the foreign bank accounts of the former President of Georgia Mikheil Saakashvili and about the death in 2005 of the former Prime Minister of Georgia Zurab Zhvania.” As noted in the press release, although the Court determined that the detention was initially valid and not principally meant to remove him from the political scene, subsequently, the main purpose of the detention became “to obtain information about Mr Zhvania’s death and Mr Saakashvili’s bank accounts. It was thus chiefly meant for an ulterior purpose not prescribed by the Convention.” The Court unanimously held that there had been a violation of Article 5 § 3 (entitlement of a detainee to trial within a reasonable time or to release pending trial) after his pre-trial detention ceased to be based on sufficient grounds, and by nine votes to eight, a violation of Article 18 (limitation on use of restrictions on rights) taken in conjunction with Article 5 § 1 (right to liberty and security). The Court also provided an overview of the existing caselaw on Article 18, noting that this case had demonstrated the need to clarify the history and use of Article 18.