The use of overly aggressive policing tactics may have a chilling effect on the right to assemble peacefully and as such may amount to a breach of Article 111: the European Court of Human Rights has held that where assemblies are peaceful police tactics must be tolerant and proportionate, even where an assembly is unlawful under domestic law2. Where policing tactics are justified by the violent nature of the demonstration, there will not be a violation of Article 113: however, such tactics must still be proportionate to the level of violence and 'heavy handed' policing may still breach Article
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