The Case of Dauletmurat Tazhimuratov

Closed Expands Expression

Key Details

  • Mode of Expression
    Public Assembly, Public Speech
  • Date of Decision
    March 10, 2025
  • Outcome
    Violation of a Rule of International Law, ICCPR Violation
  • Case Number
    Opinion No. 62/2024
  • Region & Country
    Uzbekistan, International
  • Judicial Body
    UN Working Group on Arbitrary Detention (WGAD)
  • Type of Law
    International/Regional Human Rights Law
  • Themes
    Political Expression, Violence Against Speakers / Impunity
  • Tags
    Detention, State violence, Cultural rights

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Case Analysis

Case Summary and Outcome

The United Nations Working Group on Arbitrary Detention (UNWGAD) concluded that the detention of Dauletmurat Tazhimuratov by Uzbek authorities was arbitrary and in violation of international human rights law, particularly his right to freedom of expression under Article 19 of the Universal Declaration of Human Rights (UDHR). The Government of Uzbekistan did not respond to the allegations, and the Working Group therefore issued its findings based on unchallenged claims submitted by the source. Dauletmurat Tazhimuratov was prosecuted for his peaceful activism in defense of the Karakalpak people’s cultural and political rights. The UNWGAD found that his deprivation of liberty directly resulted from the legitimate exercise of his rights to freedom of opinion and expression, freedom of peaceful assembly and association, participation in public affairs, and the cultural rights of minorities. The Working Group also noted systemic violations of due process and the absence of a legal basis for Tazhimuratov’s detention. It called for his immediate release, reparations, and urged the Government of Uzbekistan to bring its legal framework into compliance with international human rights standards. The case was referred to the relevant UN Special Rapporteurs, including those on freedom of expression, minority issues, and the independence of judges and lawyers, reflecting broader international concern over the suppression of dissent in Uzbekistan.


Facts

Dauletmurat Tazhimuratov is a lawyer, journalist, and human rights defender based in Nukus, the capital of the Republic of Karakalpakstan, an autonomous region within the Republic of Uzbekistan. He is recognized for his peaceful advocacy on behalf of the Karakalpak people, an Indigenous ethnic group native to the region, who have reportedly experienced long-standing discrimination by Uzbek authorities. This alleged discrimination has contributed to the gradual decline of the Karakalpak language and the erosion of traditional cultural practices.

In the aftermath of a violent crackdown on protesters in Karakalpakstan, hundreds of individuals were reportedly subjected to arbitrary arrest. Many, including Dauletmurat Tazhimuratov, were allegedly detained incommunicado and subjected to torture and other forms of ill-treatment. These actions were purportedly justified by the authorities based on concerns over separatism.

Furthermore, the situation has been compounded by what observers describe as a broader policy environment in which Karakalpak identity is increasingly suppressed. There have been allegations that State actions, framed as efforts to maintain national unity, have contributed to the marginalization of the Karakalpak language and culture.

The UN Committee on the Elimination of Racial Discrimination has raised concerns regarding Uzbekistan’s lack of a comprehensive anti-discrimination legislation, noting that this legal gap increases the susceptibility of minority communities—particularly the Karakalpaks—to discriminatory practices and unequal protection under the law.

Concerns were brought into sharp focus during the summer of 2022, when the Uzbek government proposed constitutional amendments that would have removed Karakalpakstan’s autonomous status. The announcement triggered mass protests throughout the region. Security forces responded with disproportionate and excessive force, including the use of firearms and stun grenades, resulting in at least 20 deaths and nearly 300 injuries.[1]

On July 1, 2022, Dauletmurat Tazhimuratov delivered a public speech in Nukus opposing the proposed constitutional amendments that would have revoked Karakalpakstan’s autonomous status. Later that day, unidentified armed and masked individuals forcibly entered his home. They detained him without presenting a warrant or informing him of the legal basis for his arrest, and a bag was allegedly placed over his head. He was reportedly beaten and subjected to the use of a stun gun. Tazhimuratov was subsequently transferred to the premises of the Ministry of External Affairs.

On July 4, 2022, law enforcement authorities located Tazhimuratov’s whereabouts and arrested him for a second time. Officials from the Ministry of Internal Affairs reportedly restrained him by tying his hands behind his back, placed a bag over his head, and subjected him to physical abuse. As with the previous arrest, he was neither informed of the reasons for his detention nor presented with an arrest warrant.

Tazhimuratov was then forcibly transported by helicopter approximately 160 kilometers to the city of Urgench. During the transfer, security personnel allegedly walked over his body and stomped on his head, further compounding the physical abuse. Upon arriving in Urgench, he was transferred to a detention facility operated by the State Security Service.

On July 5, 2022, Tazhimuratov was brought before a judge, who formally charged him, under Article 159(4) of the Criminal Code of Uzbekistan, with conspiracy to seize power or overthrow the constitutional order. The court ordered his immediate placement in pre-trial detention. Additional charges were later brought against him (though the precise timing and judicial forum remain unclear), including: large-scale embezzlement, legalization of proceeds from criminal activities, organization of mass riots, and the manufacture, storage, distribution, or display of materials threatening public security.

Tazhimuratov remained in pre-trial detention for over four months. Initially, he was held at the State Security Service pre-trial detention facility in Urgench. He was subsequently transferred to a detention center in Bukhara, approximately two weeks before the commencement of his trial. During his detention, his head was forcibly shaved, and he was reportedly subjected to harassment and intimidation by fellow detainees. These individuals were allegedly coerced by prosecutors and other officials into providing false testimony against him.

Tazhimuratov’s trial began on November 28, 2022, before the Bukhara Regional Criminal Court. He was tried alongside 21 co-defendants, all accused of offenses allegedly connected to the July 2022 protests in Karakalpakstan.

The prosecution’s case relied heavily on testimony and analysis from State-appointed experts. Notably, none of these experts was proficient in the Karakalpak language, which precluded a proper evaluation of evidence in its original linguistic and cultural context.

Tazhimuratov and his legal counsel were reportedly denied the opportunity to assess the qualifications or impartiality of the interpreters involved. His request to engage independent expert witnesses was also rejected by the court, undermining the principle of equality of arms. Additionally, it was alleged that authorities deleted audio recordings of Tazhimuratov’s conversations with government officials—evidence he had intended to submit in his defence.

Throughout the proceedings, Tazhimuratov was confined in a glass enclosure within the courtroom, a practice that may have impeded effective communication with his legal representatives. The courtroom’s live broadcast was reportedly suspended at the moment Tazhimuratov described the acts of abuse and ill-treatment he suffered while in detention.

On 31 January 2023, Tazhimuratov was convicted on all counts and sentenced to 16 years imprisonment, in addition to being ordered to pay approximately US$20,000 in damages. On 5 June 2023, the Supreme Court of Uzbekistan upheld both the conviction and sentence, despite reducing the penalties imposed on several of his co-defendants.

Tazhimuratov is currently serving his sentence at Prison Colony No. 11 in Navoi. Reports indicate that he is subjected to poor-quality food and inadequate medical care, with prison authorities allegedly prescribing identical medications for unrelated health conditions.

Officials have reportedly compelled him to express gratitude for access to basic necessities and denied him access to news, radio, television, or educational materials, thereby isolating him from external information and human contact.

Tazhimuratov has also allegedly been ordered to sing the national anthem of Uzbekistan and was punished for refusing to do so. While his lawyer has filed a new appeal, the State Security Service has reportedly threatened individuals who attempt to speak to the media about his imprisonment.


[1] Amnesty International, Uzbekistan: End use of unlawful force against Karakalpakstan protesters (4 July 2022) https://www.amnesty.org/en/latest/news/2022/07/uzbekistan-end-use-of-unlawful-force-against-karakalpakstan-protesters/; Human Rights Watch, Uzbekistan: Police Abuses in Autonomous Region Protests: Excessive, Lethal Force in Karakalpakstan (7 November 2022) https://www.hrw.org/news/2022/11/07/uzbekistan-police-abuses-autonomous-region-protests.


Decision Overview

The United Nations Working Group on Arbitrary Detention (UNWGAD) delivered Opinion No. 62/2024 concerning Dauletmurat Tazhimuratov. The central issue before the Working Group was whether the arrest and detention of Tazhimuratov by Uzbek authorities, arising from his peaceful advocacy on behalf of the Karakalpak people’s cultural and political rights, were compatible with international human rights standards prohibiting arbitrary detention. Specifically, the Working Group examined whether his deprivation of liberty resulted from the legitimate exercise of his rights to freedom of opinion and expression, peaceful assembly and association, participation in public affairs, and the right of minority communities to enjoy their culture.

No legal basis for detention

At the outset of its analysis, the UNWGAD considered that  Tazhimuratov was neither presented with a valid arrest warrant nor promptly informed of the reasons for his arrest or the charges against him, in violation of Articles 3, 8, and 9 of the Universal Declaration on Human Rights (UDHR) and Principles 2, 4, and 10 of the Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment—which collectively protect essential human rights relating to life, liberty, security, and justice. He was subjected to two violent arrests without due process, and formal charges were filed only after significant delay.

Furthermore, his detention was based on vague and overly broad provisions from Uzbekistan’s Criminal Code (articles 159, 244, and 244-1), which criminalize lawful expression and assembly under the pretext of combating “extremism,” the UNWGAD stated. These laws fail to meet the requirement of legality under Article 11(2) of the UDHR and Article 15(1) of the International Covenant on Civil and Political Rights (ICCPR), as noted by UN Special Rapporteurs. The UNWGAD highlighted that reliance on such imprecise statutes to suppress dissent rendered Tazhimuratov’s detention arbitrary and incompatible with international law.

Violation of freedom of expression

The UNWGAD considered the deprivation of liberty of Tazhimuratov to be arbitrary, as it stemmed directly from the legitimate exercise of his internationally protected rights to freedom of expression, peaceful assembly, association, participation in public affairs, and the cultural rights of minorities.

As noted by the Working Group, Tazhimuratov was arrested, prosecuted, and sentenced to 16 years of imprisonment following a public speech in which he voiced opposition to constitutional amendments perceived as undermining the autonomous status of the Karakalpakstan region.

In addition to his political expression, Tazhimuratov called for peaceful demonstrations in support of the Karakalpak people’s cultural and administrative autonomy. These acts were subsequently criminalized under Uzbekistan’s Criminal Code. These provisions have been widely criticized by international human rights mechanisms, including United Nations Special Rapporteurs and the UNWGAD, for their vague formulation and for being employed to suppress dissenting political speech and peaceful activism.

In accordance with established international standards, the Working Group reaffirmed that peaceful political expression, including criticism of the government and advocacy for minority rights, falls within the core scope of protections of Article 19 of the UDHR and articles 19(1) and (2) of the ICCPR. These provisions guarantee the right to seek, receive, and impart information and ideas of all kinds, regardless of frontiers. The Working Group emphasized that such rights are foundational to democratic governance and must not be curtailed on vague or politically motivated grounds.

Upon evaluating the legitimacy of the restrictions imposed, the Working Group applied the three-part test articulated in Article 19(3) of the ICCPR and Article 29(2) of the UDHR, under which restrictions on freedom of expression must:

(1) be prescribed by law.

(2) pursue a legitimate aim, such as the protection of national security, public order, or the rights of others.

(3) be necessary and proportionate to achieve that aim.

The Working Group concluded that Uzbekistan failed to satisfy any of these criteria, as there was no evidence that Tazhimuratov’s speech incited violence or posed a concrete threat to national security or public order. Rather, his actions were a form of peaceful and constitutionally guaranteed political participation.

In addition to freedom of expression, Tazhimuratov’s conduct implicated the rights to peaceful assembly and association, protected under Article 20(1) of the UDHR and articles 21 and 22 of the ICCPR. These rights encompass not only the act of assembly itself, but also the preparatory stages—such as organizing, mobilizing resources, and disseminating information about a forthcoming event. The prosecution of Tazhimuratov for engaging in such conduct was thus incompatible with the State’s obligations under international human rights law, the UNWGAD concluded.

 Violation of the right to a fair trial

Although the UNWGAD determined that no trial should have taken place in light of its findings, it proceeded to assess the alleged fair trial violations. The Working Group considered the uncontested reports that Tazhimuratov was subjected to ill-treatment and torture from the moment of his initial arrest. It was “particularly disturbed” by the fact that these allegations were raised during trial but met with judicial inaction—notably, the trial court allegedly shut off the livestream during Tazhimuratov’s testimony about the abuse.

This failure to investigate or respond to Tazhimuratov’s allegations violated the right to an independent and impartial tribunal, as protected under Article 10 of the UDHR and Article 14 of the ICCPR, the UNWGAD considered.

The Working Group also found a breach of the equality of arms principle. As noted by the UNWGAD, prosecution-appointed experts evaluating Tazhimuratov’s speech did not speak Karakalpak, his native language, while the defence was denied access to independent experts and crucial exculpatory audio evidence, which authorities had reportedly deleted. Thus, the court’s conduct, favouring the prosecution and disregarding the rights of the defence, was deemed incompatible with judicial impartiality, in violation of Article 14(1) of the ICCPR.

The cumulative due process violations, including denial of an impartial tribunal and the suppression of defence evidence, led the Working Group to conclude that Tazhimuratov’s detention was also arbitrary under international la.w

Discrimination on the basis of nationality and political opinion

The UNWGAD held that Tazhimuratov’s detention was also arbitrary, as it resulted from discrimination on the basis of both nationality and political opinion.  To the Working Group, Tazhimuratov was targeted for peacefully expressing opposition to constitutional amendments threatening Karakalpakstan’s autonomy, a position closely tied to his ethnic and political identity.

On this point, the UNWGAD, recalled that detention is considered discriminatory when it disproportionately affects individuals on grounds such as national origin or political belief, particularly in contexts involving systematic repression. The source reported that Karakalpak political activists, including non-governmental organizations and individuals living abroad, were subjected to widespread targeting. This targeting included mass detentions and the excessive use of force against Karakalpaks and opponents of the proposed constitutional amendments, demonstrating a broader pattern of discrimination based on nationality and political opinion.

The Working Group further noted that the experts who testified against Tazhimuratov were unfamiliar with the Karakalpak language, raising serious concerns regarding equality of arms and cultural discrimination during trial proceedings.

In light of these circumstances, the UNWGAD concluded that Tazhimuratov’s detention violated articles 2 and 7 of the UDHR and articles 2(1) and 26 of the ICCPR, as well as Article 18 of the Constitution of Uzbekistan, which guarantee equality before the law and prohibit discrimination.

Considering these findings, the UN Working Group on Arbitrary Detention requested the Government of Uzbekistan to take immediate steps to remedy the situation, including releasing Tazhimuratov and providing him with an enforceable right to compensation and other reparations in accordance with international law. It further urged a full and independent investigation into the circumstances of his arbitrary deprivation of liberty and appropriate measures against those responsible.


Decision Direction

Quick Info

Decision Direction indicates whether the decision expands or contracts expression based on an analysis of the case.

Expands Expression

This opinion expands the protections of freedom of expression and minority rights by affirming that peaceful advocacy for cultural autonomy is protected under international law. The UNWGAD condemned the use of vague national security laws to silence dissent and found that Tazhimuratov’s detention was not only arbitrary but also discriminatory on the basis of nationality and political opinion.

The decision underscores that expression related to Indigenous identity and political participation cannot be criminalized, and that trials must respect linguistic and cultural rights to ensure fairness. By ordering Tazhimuratov’s release and reparations, the Working Group reinforces international standards against the repression of ethnic minorities and peaceful activists.

Global Perspective

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Global Perspective demonstrates how the court’s decision was influenced by standards from one or many regions.

Table of Authorities

Related International and/or regional laws

National standards, law or jurisprudence

  • Uzbek., Criminal Code of Uzbekistan, art. 159(4)
  • Uzbek., Criminal Code of Uzbekistan, art. 244
  • Uzbek., Constitution of Uzbekistan, art. 18

Case Significance

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Case significance refers to how influential the case is and how its significance changes over time.

The decision establishes a binding or persuasive precedent within its jurisdiction.

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