Students Access to the Internship Economic-Legal Importance
Keywords:Professional Career, Student Internship, Economic-Legal Context, Employer, Employee, Protection
The availability of internships is determined by the interest of accepting interns if the conditions are agreed. Georgia is a legal and social state which means that the main function of the legislator is to establish the new norms in the relations of the parties, or to stop actions from regulation.
The state and universities have a special functions. There are numerous relations between the economic and legal meanings. The role of the state is considered ambitious. Not only regulation, but also abstention may be a defining the role, so that the legal context does not constrain economic significance. It is necessary to determine which should be implemented on the relations between the parties. The basis of the legislative change may be determined by various reasons but the purpose of this change should be correctly seen.
Keywords: Professional career, student internship, economic-legal context, employer, employee, protection
In the economic integration with the European Union, the Georgian model of internship can be compared with the Law of the Republic of Lithuania, which considers unpaid employment of a person as performing work for an employer under a voluntary internship contract or a professional internship contract (Law of the Republic of Lithuania “On Employment”, 2016). 
Lithuania belongs to the group of EU states that prefer to define the concept of internship and the status of an intern. The matching of the voluntary internship agreement (See note)  is an unpaid internship. In contrast, the professional internship agreement in Georgian reality implies an internship defined by a special law, which requires a previous internship to enter the profession, for example, a lawyer, notary or judge (See note).  Unpaid voluntary internships are regulated in Lithuania, so comparing the legal structure of internships, the terms, purposes, and ages are important.
The university’s role has changed in cooperation with main actors operating in the labor market, which means providing students with information about internships (Dyrnes, 2011).  The certain faculty is authorized to create an internship opportunity within the framework (See note) , thus preparing the student to better understand the internships (Hora and others, 2019 / Skiadas and others, 2021).  The growing interest and the continuous structure of the problem cases determine the relevance of the cooperation between the state and the university. It is necessary to maintain economic context (The General Proposal “On the Issue of Preventing and Fighting Against Discrimination”).  The possible cooperation between organizations and higher education institutions will contribute to the planning of the actions to improve the situation.
- European Directives
The purpose of the Directive of 14 October 1991 on the establishment of mechanisms for the treatment of employees and the transparency of labor relations includes the need to clarify the means of achieving this goal and the obligations. The standards stipulated by the directive apply to the labor relationship, and for the implementation of the legal mechanism, it is important to have an appropriate norm on the labor relationship. The state of the directive has the right not to apply the standard defined by the directive to contracts for which the establishment of an exceptional rule is part of the directive’s objective.
The directive establishes the following: Within two months after the beginning of the employment, the employer must provide the employee with information about the essential conditions or employment contract. Also, the obligation to inform the employee may be extended directly but is a relevant condition of the contract. Also, if the essential conditions are defined in detail in the contract, the employer is not obliged to transfer an independent document, and in the case of a non-written form of the contract, the document with an independent form contains a value. The obligation of states to create effective protection legal mechanisms and accessible justice is important. The employee’s right to request information from the employer by applying to the court addresses the same issue.
The purpose of the Council Directive of 28 June 1999 is to protect persons employed on fixed-term and temporary contracts against unequal treatment and the conclusion of a fixed-term employment contract. To achieve the goal, the following standards are defined: treating persons employed on a fixed-term job differently is prohibited when the advantage is not based on any objective circumstances. Also, it is not allowed to give preference to a person employed for life without any objective reason. Significantly, the addressee states of the directive have the obligation to develop mechanisms that are the normative bases of legal protection necessary for implementing the purpose of the directive.
The recommendation operating at the level of the Union, which regulates the issues of internship, has a non-binding character. The Recommendation “Quality Framework for Internships” defines the concept. Based on the above, the following types of internships: internships within the educational program of a higher educational institution or cooperation signed by the university, mandatory internships to acquire professional skills, internships in the field of public service in various institutions and internships operating in the labor market, which are referred to as open market internships (Leonidze, 2022). 
- Distinguishing Internships
One of the main means of ensuring the labor right (Constitution of Georgia, 24/08/1995, Article 26 / Putkaradze, 2013 / Arevadze, 2021) is the regulation of the signing of the contract for a specified or indefinite period. According to certain opinions, based on the fact that “everyone has the right to freely choose a job” (Constitution of Georgia, 24/08/1995, Art. 26) , the legislator should not determine economic, legal or other advantages between the contract and internship. However, the rules for their separation and legal burden should be established.
An internship contract, which must be concluded in writing for a specified period, does not differ from an employment contract but is essentially different from it in terms (Jorbenadze, 2012) . It is necessary to consider the parties' desire to choose between the internship contract and the labor contract according to their interest.
The purpose of concluding an employment contract is to reflect, on the one hand, the conditions of the organizational arrangement of labor, and on the other hand, the content and conditions of work performance in the contract, in exchange for compensation for the employer (Labor Code of Georgia, 17/12/2010).  The purpose of the internship contract is not focused only on the performance of work, but at the same time, it is highly formal and conditional - it lacks
the possibility to determine the specific purpose of employment. Therefore, the goal criterion is insufficient to consider the expected outcome further. The purpose and duties may be different from each other. To determine the result, the mentioned classifier needs other classifiers.
The parties of the contract are the employer and the employee. Significantly, the organization receiving the intern is the employer, although in the context of the “weak” party, the employee and the intern have different legal statuses. An employee is called on an employment contract, and an intern is called an intern on an internship contract. The question is how weak an intern’s legal status is compared to an employee’s.
The term of validity of the labor contract is determined for a specified or indefinite period, taking into account the Article 12 of the Labor Code of Georgia. It makes possible to determine the duration of the labor relationship within the framework of freedom of labor in terms of short and long-term or life-long conditions. The internship is given only for a specified period, where the criterion for determining the maximum period is the issue of remuneration.
In contrast to internships, the limitation of the number of times of entering into an employment contract does not apply to the same or different employers, in individual cases, such a limitation may have a specific legal basis regarding the conclusion of a contract for a definite or indefinite period, which is not related to the purpose for which the number of times of entering into an internship contract is limited. The place and time of performance of the work determined by the labor contract is determined by the condition of the organizational arrangement of the work. On the contrary, Article 18 of the Labor Code does not establish any other regulation of the place and time of work performance. This is within the scope of the parties' agreement, provided that the minimum standard of protection will be applied to the intern. In light of the fact that the place and time of the employment contract are more regulated, the scope and extent of the spread of this regulation is unclear in relation to internships.
The rights and obligations of the parties to the labor contract are determined by the contract of the parties (Chachava, 2014).  Determining the rights and obligations of the parties based on the contract may be a distinguishing criterion considering the content of the mentioned (Chachava, 2011) , although this cannot prevent unintended cases of cooperation. Different guarantees in employment contracts and internships are established in each case. It is worth noting that legal disputes related to internships have not been registered in the Tbilisi City Court (Letter №2-0144/5686404).  This is against the background that from 2020 to the present, 79 cases or 27.4% of the 288 cases referred to the Mediation Center of the Tbilisi City Court were related to labor legal disputes (Letter №3-0455/5755914).
The issues of work experience obtained as a result of the employment contract are not relevant to the internship contract, which is a differentiating criterion, but the differences obtained based on one criterion taken separately will not be able to eliminate the complex problems.
A number of distinctive legal circumstances characterize the relationship between the employment contract and the internship, although it is difficult to determine the chronological sequence among them because the completion of the internship before the deadline or successfully cannot be a determining factor for the conclusion of the employment contract. Disguising the labor contract with an internship is practically possible, and it is dangerous that the legislator reveals in Article 18, Clause 2 of the Labor Code of Georgia. Nevertheless, this threat cannot be one, it is characterized by diversity depending on the content of the relationship and requires the development of a different preventive mechanism for each form of threat (Holford, 2017).  This implies that the content of the internship regulated by Article 18 of the Labor Code of Georgia may not fit within the scope of this norm, which is why the employer treats the intern unequally. The heterogeneity formed in accordance with the attitude may indulge the intern’s interest.
The dangers of disguising the employment contract with internships are based on Article 18, paragraph 2, which is largely informative (Letter №09/2150).  The danger of disguising an employment contract with an internship is caused by a) the employer’s use of the work performed by the intern to avoid concluding an employment contract with him or another person in the future (Labor Code of Georgia);  b) the desire of the employer to replace the employee with an intern, to create such a factual circumstance that, at the expense of the internship, the work performed by the intern is usually performed by the employee (Ibid);  c) the employer’s decision to hire an intern instead of the employee whose employment relationship has been suspended or terminated (Ibid).  If the legal status of the intern at the legal level is equipped with protective guarantees, then the dangers of masking the labor contract with an internship will be regulated at the expense of self-regulation and self-creation of preventive mechanisms when the intern will have sufficient legal leverage and resources to protect his rights. To develop protective legal levers, it is not enough to strengthen the labour inspectorate’s role in controlling the guarantees of the legal protection of interns (Special Report on the Fight against Discrimination, 2016).  It is necessary to directly strengthen the legal status of the intern and integrate it into the existing legal reality by strengthening the economic aspects and sustainability.
It is worth noting the relationship of the probationary employment contract with the internship, which aims to determine the individual’s suitability for the work to be performed. The goal here is different (Takashvili, 2021).  A specific goal of compliance with the work to be performed is outlined. The target component difference refers to the anticipation of expected activity. In the case of an internship, the purpose or interest of the employment is not even considered at the legislative level. The parties to the probationary employment contract are the employer and the probationary employee with whom the probationary employment contract is concluded. Therefore, he is a party to this contract, that is, he is employed (Beridze, 2020). 
The term of validity of the labor contract concluded with a trial period is no more than six months. Also, the maximum validity period of the unpaid internship contract is six months. There is a limitation on how many times a probationary employment contract can be concluded. A trial period labor contract with the same employee is signed only once.
The place and time of performance of the work established by the labor contract concluded with the trial period is determined by the Labor Code of Georgia. The rights and duties of the parties to the labor contract concluded with a trial period are determined by the parties' agreement in the contract signed between them. The internship contract is also the carrier of this goal, although the risk of the difference between the written and practically implemented functions should still be considered. A probationary employment contract is more focused on signing an employment contract for that person than an internship contract.
Different guarantees in the case of a probationary employment contract and an internship are related to the specific nature of the employment opportunity because “the employer has the right to conclude a fixed-term or permanent employment contract with the employee at any time during the probationary period”. (Labor Code of Georgia).  In the case of an internship contract, the purpose or interest of employment is not considered at the legal level. The form of an employment contract concluded with a trial period is only in writing, as in the case of an internship contract. The legislation provides the possibility of counting the term of the labor contract concluded with a trial period in the work experience, unlike the internship contract. The internship contract is not directly characterized by the purpose of employment, which gives it an essentially different legal character. The legislator did not consider it reasonable to consider the objective component of the internship only for employment, however, it left an open space / raised the risk for a separate party to the internship agreement to exclude this goal altogether. A probationary employment contract and an internship contract, despite the similarity of a separate legal classifier, are essentially contracts of different forms, content and purpose (See note). 
- Typology of Disputes
Statistical recording and processing of information and court decisions, requested in connection with Article 18 of the Labor Code of Georgia regarding the subject of the dispute, is currently not carried out in the Tbilisi City Court (Letter №2-0144/5686404).  Because court decisions are not sought, it is impossible to determine the relationship of Article 18 of the Labor Code with other types of disputes (See note) , taking into account the data of the Tbilisi City Court. Therefore, it is appropriate to review the practice of the civil and administrative chambers of the Supreme Court of Georgia, based on the typological characterization of the internship, when the court evaluates the internship with different objective functions.
From the factual circumstances of one of the cases of the Civil Affairs Chamber of the Supreme Court of Georgia, it is established that the plaintiff participated in the competition, which meant the opportunity to undergo an internship in public institutions of a foreign country and increase professional qualifications (Decision №3k/1188-02).  He won the competition, however, due to various objective reasons, the citizen was refused a visa to a foreign country, due to which he was deprived of the opportunity to undergo an internship physically, which is why he demanded compensation for material and moral damages. The court explained that the plaintiff’s fault caused the non-implementation of the internship opportunity because he hid and did not fully submit information to obtain a visa.
In another case, the defendant was sent to a foreign university for an internship based on an order. Two years after completing the internship, due to the plaintiff’s termination of the labor contract, the defendant was informed that he should reimburse the double amount of the expenses incurred for the training to improve his qualifications, as this condition was stipulated in the contract. The court explained that the secondment for the purpose of internship did not mean only qualification improvement, and the internship had a different target load, both for the defendant and for the employer-plaintiff. Accordingly, the labour contract clause, on which the employer demanded the reimbursement of the double amount of the incurred expenses, was not taken into account for charging the amount to the defendant (Decision №As-1300-1220-2015). 
The court assessed whether the defendant enterprise had an obligation to provide internships within the departmental sub-location for those who needed to undergo internships to obtain the necessary qualifications for occupying the relevant professional rank. It was determined that the defendant’s obligation may be based on several legal acts, namely the law, the decree and the rule of internship (Boron, 2016).  The defendant relied on the resolution of the Government of Georgia, which was applicable to this institution, and at the time of the submission of the request by the plaintiffs, it did not provide for the imposition of a similar obligation on the defendant. In another case, when evaluating a probationary contract, the court pointed to a case of lack of internship, which was determined by the fact that the plaintiff did not complete a theoretical and practical course, did not participate in an exam to be conducted for evaluation purposes, and was directly transferred by the employer to a short-term labor contract (Decision №As-1300-1220-2017). 
The court found that the employer violated the terms of the pharmacy practice contract when, according to the contract, the individual had to undergo a 1-month internship, and after the successful completion of the internship, the employer had to appoint the intern to the appropriate position. The fact that completing an internship was a prerequisite for signing an employment contract was determined by the parties' agreement, later by the pharmacy practice contract (Decision №As-1500-1420-2017).  In another case, the subject of the dispute was “recognition of the conclusion of the general inspection and the order on the termination of the employment relationship, provision of equal work, compensation of the employee”. (Decision №As-533-533-2018).  This dispute is interesting because it mentions the problem created by lacking a general definition of internship in a public institution. There are reports about the firmly established practice in the institution that the procedure for passing the internship, the basic conditions, and the issues of accepting and terminating the intern should have been regulated by an individual act of the institution’s leaders. The subject of discussion was the legality of signing the internship, considering the equal importance of both the contract and the individual administrative-legal act. Nevertheless, the Court of Cassation did not appreciate the legal nature of the internship and considered that the dispute did not represent a rare legal problem that would contribute to the development of the law.
The plaintiff was not allowed to hire interns or volunteers to manage the flow of a particularly voluminous case. Also, he had a problem with the employer when he passed on the interns' request not to do the internship on a non-working day (Decision №As-411-411-2018).  The court noted that only the plaintiff was not allowed to hire interns, which is why the plaintiff had the smallest support staff despite the large number of cases (Decision №As-634-2021).  Nevertheless, the employee does not have the right to hire an intern independently at the workplace because the parties to the internship contract are directly the intern and the employer.
Considering the short period of internship, the court discussed the inappropriate and insufficient evidence of the testimony of intern witnesses, while the explanations of these persons should be the basis for the application of a specific disciplinary measure against the employee of this institution and the assessment of possible disciplinary misconduct revealed during the period of activity (Decision №As-119-2020). 
From the decisions of the Chamber of Administrative and other categories of cases of the Supreme Court, the following is worth noting: the plaintiff was appointed as an intern at the training centre of the General Prosecutor’s Office of Georgia for the vacant position of prosecutor, after the expiration of the 2-year internship period, he was dismissed from the institution on the grounds of impossibility of appointment as a prosecutor, as no positive recommendation and petition for appointment to the position was issued. The court explained that according to the rule in force at the institution, the maximum period of the internship was two years, the expiration of which makes it impossible to continue the internship again under the same conditions (Decision №3G-AD-338-K-02).  The institution may take a positive or negative decision on appointing a person to a position. Therefore, extending the internship period to postpone the appointment decision is inappropriate. In another case of the Chamber of Administrative and Other Categories of Affairs, the plaintiff requested that the Ministry where he was employed be instructed to second him for a 1-year internship in another institution. The court explained that the secondment of an existing employee for an internship is a discretionary power of the administrative body and not an obligation (Decision №3g-ad-16-k-03).  Also, the possible approval of the administrative body does not unconditionally give rise to the right of the person wishing to undergo an internship to request promotion.
The plaintiff was not accepted for an internship at the Georgian Bar Association because the university mistakenly issued a diploma to him; his qualifications were not mentioned in the plaintiff’s diploma. Following the claimant’s appeal, the university issued a new degree but informed the bar association that the claimant’s qualification was not a lawyer but a business lawyer. The claimant considered the said notification to be an illegal act. Correct evaluation of the qualifications of the person wishing to do the internship as a prerequisite became the subject of the court’s reasoning, although the importance of the internship was not discussed in the content (Decision Bs-143-321-K-03). 
The plaintiff requested the annulment of the individual administrative-legal act and reinstatement as an intern. The plaintiff’s internship was terminated in accordance with the applicable internship rule at the institution because he was a conflicted person. However, the legal basis for the termination was not specified. The court assessed the justification of the individual administrative-legal act issued based on Article 18 of the rule of internship in the Ministry of Economic Development of Georgia. It was established that the administrative body failed to ensure the assigned obligation - to establish the fact of violation of a specific rule by the intern and did not properly report the issue, which it did not study enough (Decision №Bs-825-787(K-07). 
Judicial practice and the typology of disputes arising from the relationship testify that the legal nature of the internship in the practice of the Supreme Court of Georgia is determined by taking into account the subject of the dispute, and it does not include complete substantive concepts.
The role of the labor inspectorate is important until other additional means of solving the existing problems are developed. Therefore, within the existing capabilities and powers, the actions of the labor inspection in the field of control of guarantees of the legal protection of interns should be specifically planned in relation to the various bases of Article 18 of the Labor Code. For effective management, existing deficiencies should be corrected first, and then planned and staged inspections should be carried out. Socio-economic issues are still forgotten.
It is desirable to determine the minimum and reasonable compensation, which implies the admissibility of cancelling the internship without compensation and the legal regulation of the internship only in paid form, by resolving the question of frequency and duration. At the same time, it is advisable to consider the internship as work experience. This will strengthen the purpose and repeatability of the internship in different organizations. It is permissible to advance the goal of employment in the future in the first paragraph of Article 18 of the Labor Code and to develop solid guarantees of the intern’s socio-economic rights. The development of guarantees of the socio-economic rights of the intern ensures the perception of the independent nature of the intern’s legal status for the parties to the internship agreement, including the perfect implementation of the goal of the internship and the compliance of the work to be performed with the same purpose.
It is significant to discuss the articles 168, 169 and 170 of the Criminal Code of Georgia in the legal context of the internship agreement (Lekveishvili and others, 2016) , to what extent it is possible to spread criminal liability to the parties of the internship agreement for qualification under the discussed norms (Criminal Code of Georgia, Criminal Code).  The crime in Article 168 of the Criminal Code of Georgia belongs to the group of formal crimes when a person is prevented from performing legal labor activities by violence or threats (Lekveishvili and others, 2016).  Also, the violation of the labor legislation provided for in Article 169 is formal, which means that for the classification of the crime, the occurrence of the result is not important, and it is enough when a person is forced to write a statement about leaving work, and/or when a supervisor does not comply with a court decision on this person’s work regarding recovery. Violation of labor protection rules punishable under Article 170 belongs to the group of material crimes and is a two-objective crime committed by negligence (Criminal Code of Georgia).  All three named norms refer to Article 26 of the Constitution of Georgia and the labor legislation of Georgia, and further aim to strengthen and support the protection of the labor rights of citizens, although they do not provide for the imposition of responsibility on the parties to the internship agreement (Lekveishvili and others, 2016).  The subject of discussion is whether criminal liability should be imposed on the parties to the internship agreement by introducing a new norm in the corresponding chapter of the Criminal Code only after the internship institution is fully regulated in the Labor Code of Georgia (See note).  There is an opinion that the spread of criminal liability to the parties of the internship contract will ensure the legal risks related to the internship and strengthen the parties' position (Jishkariani and others, 2020).
Georgia is in the active process of economic integration with the European Union, where the implementation of planned actions for students' access to professional advancement occupies a special place. The legal structure of internship and the qualifying characteristics of separation from labor and probationary contracts are characterized by the need for scientific research and the development of effective legislation in Georgian law. Regarding the regulation of internships in the labor market, conflicting opinions are discussed, and the importance of internships in the context of access to the professional advancement of interns is critically evaluated, where the need to clarify the dangers of disguising the labor contract with an internship determines the need for legal guarantees and regulation of the protection of the rights of interns.
Based on the fact that the legislator considered it necessary to regulate the legal status of the intern in the labor market, this mustn't be based only on the formal beginning because there is an association - the concept of abstaining from the direct regulation of socio-economic rights and other fundamental issues. In this case, if the legislator does not consider it appropriate to develop guarantees of socio-economic rights in Article 18 of the Labor Code of Georgia, then it is entirely acceptable to establish protective mechanisms in other norms of the Labor Code of Georgia, taking into account the content context.References:
- Law of the Republic of Lithuania “On Employment” (2016). Art. 9, Par. 5-6.
- It was implemented in 2015. The age limit of the contracting party was determined from 16 to 29.
- When the candidate for the position of judge is a student of the Higher School of Justice.
- Dyrnes, I. (2011). Interns Revealed: a Survey on Internship Quality in Europe. European Youth Forum Materials, 27-28.
- See the Concept of the Law Faculty of Ivane Javakhishvili Tbilisi State University, Art. 31, Par. 2 (f).
- See: Hora, M. T., Chen, Z., Parrott, E., Her, P. (2019). Problematizing College Internships: Exploring Issues with Access, Program Design, and Developmental Outcomes in Three U.S. Colleges. University of Wisconsin–Madison, Working Paper №1, 12-13; Skiadas, D., Boutsiouki, S., Koniaris, V., Zafiropoulos, K., Karatsiori, M. (2021). Developing Student Work Experience Programmes Within the European Higher Education Area Framework: The Role of Social Partners, Journal of International Education Studies, Vol. 14, №11, 37-38.
- The General Proposal “On the Issue of Preventing and Fighting Against Discrimination”.
- Leonidze, I. (2022). The Legal Nature of Internship and the Qualifying Characteristics of Separation from Labor and Probationary Contracts, Master’s Thesis/TSU, 6.
- See: Constitution of Georgia, 31-33, 24/08/1995, Article 26, Putkaradze, I. (2013). Freedom of Labor, Commentary on the Constitution of Georgia, Article 30, 367-368; Arevadze, N. (2021). The Principle of the Social State: Practice of the Constitutional Court, Journal of Constitutional Law, №1-2, 197-198.
- Constitution of Georgia, 31-33, 24/08/1995, Article 26,
- Jorbenadze, S., Action of Separate Legal Institutions of the Civil Code in Relation to the Labor Code, №1-2(3-4), 2012, 14-15.
- Labor Code of Georgia, 17/12/2010, Art. 2, Par. 1.
- Chachava S. (ed.), Legal Aspects of Changes in Labor Law, 2014, 30-31.
- Chachava S., Analysis of Georgian Labor Law - Problems and Recommendations, 2011, 20-21.
- See: Letter №2-0144/5686404.
- Letter №3-0455/5755914.
- Holford, A. (2017). Access to and Returns from Unpaid Graduate Internships, Institute of Labor Economics (IZA) Discussion Paper Series, №10845, 1-2.
- Letter №09/2150.
- Labor Code of Georgia, Art. 18, Par. 2.
- Special report on the fight against discrimination, its prevention and the state of equality, 2016, 44, 60.
- Takashvili, S. (2021). The Proof Process in the Dispute Arising from the Termination of the Probationary Employment Contract, Justice and Law, №3(71), 128-129.
- Beridze, S. (2020). Practice of the Supreme Court of Georgia on Labor Disputes, Labor Law Review, №1, 46-47.
- Labor Code of Georgia, Art. 17, Par. 3.
- The question is how much is allowed when the probationary period is not locked by the internship completed in the same place.
- Letter №2-0144/5686404.
- Nor was any dispute related to Article 18 found in the Mediation Center of the Tbilisi City Court.
- Decision of the Supreme Court of Georgia, №3k/1188-02, 16/12/2002.
- Decision of the Supreme Court of Georgia, №As-1300-1220-2015, 26/02/2016.
- Boron, A. (ed.). Commentary on the Labor Code of Georgia, 2016, 79.
- Decision of the Supreme Court of Georgia, №As-1300-1220-2017, 5/03/2018.
- Decision of the Supreme Court of Georgia, №As-1500-1420-2017, 31/05/2018.
- Decision of the Supreme Court of Georgia, №As-533-533-2018, 22/06/2018.
- Decision of the Supreme Court of Georgia, №As-411-411-2018, 14/11/2018.
- Decision of the Supreme Court of Georgia, №As-634-2021, 4/11/2021.
- Decision of the Supreme Court of Georgia, №As-119-2020, 23/02/2022.
- Decision of the Supreme Court of Georgia, №3G-AD-338-K-02, 30/10/2002.
- Decision of the Supreme Court of Georgia, №3g-ad-16-k-03, 26/03/2003.
- Decision of the Supreme Court of Georgia, №Bs-143-321-K-03, 27/01/2004.
- Decision of the Supreme Court of Georgia, №Bs-825-787(K-07), 22/01/2008.
- Lekveishvili, M., Todua, N., Mamulashvili, G. (2016). Private Part of Criminal Law, Book I, 6th, 373.
- Criminal Code of Georgia, Criminal Code, 22/07/1999, Art. 168.
- Lekveishvili, M., Todua, N., Mamulashvili, G. (2016). Private Part of Criminal Law, Book I, 6th, 374.
- Criminal Code of Georgia, Art. 169.
- Lekveishvili, M., Todua, N., Mamulashvili, G. (2016). Private Part of Criminal Law, Book I, 6th, 377.
- It is a subject of the discussion the composition of Article 168 of the Criminal Code of Georgia.
- Jishkariani B., Vasmer P. M. (ed.), German-Georgian Law Dialogue, Conference Materials, 2020, 11-12.
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