Digital Vigilantism in Kyrgyzstan: Legal Gaps and Institutional Responses

Today, Plovism proudly features a guest post by a bright student of the OSCE Academy in Bishkek, Samir Sultanov. Samir is in the final stretches of the MA in Politics and Security program. His academic interests include cybersecurity, disinformation, and narrative control in the context of contemporary conflicts. In this post, Samir offers policy recommendations for tackling digital vigilantism in Kyrgyzstan.

Digital Vigilantism in Kyrgyzstan: Legal Gaps and Institutional Responses

Introduction and policy challenge

In 2023, in Kyrgyzstan, a Telegram channel "Youth Group Against Pedophilia" began posting videos of its members beating and intimidating people they deemed "pedophiles" without any official evidence. The attacks were filmed and immediately shared on the channel alongside calls for reprisals. The descriptions explicitly mentioned engaging 16- to 19-year-olds "in educational activities" and collecting donations; within a short time, the channel had amassed over 3,000 subscribers. The Kyrgyz Ministry of Internal Affairs publicly stated that "an investigation is underway," although no statements from victims had been received. In other words, although the violence and calls for violence were documented in the publications themselves, no publicly known investigation results were announced (Azattyk 2023; Kloop 2023).

In retrospect, it would be wrong to view this news as an isolated incident of illegal activity by a single group. In fact, this is a persistent practice, manifested in the coordination of violence and harassment via messaging apps and social media, followed by public "approval." Such outbreaks have already occurred in Kyrgyzstan in the past: from the "moral raids" of the nationalist group Kyrk Choro, which published "exposé" videos (2014–2015), to the mobilisation of crowds and attacks on foreign student dormitories in Bishkek in May 2024 after videos were distributed online (Eurasianet 2015; Reuters 2024).

This form of citizen-led justice mediated online can be referred to as digital vigilantism. The phenomenon spans actions of individuals or groups dissatisfied with the behaviour of others, who then retaliate by using online platforms to expose, publicly condemn, or mobilise public pressure (Trottier 2017, 56).

Why is this problematic for the state and society?

Since digital vigilantism is an act of self-initiated citizenry, it can have serious ethical and legal consequences. Digital vigilantism undermines the foundations of the legal system by circumventing formal procedures and due process guarantees (Doležal 2024). It shifts the presumption of innocence towards the presumption of guilt and deprives the alleged offender of the opportunity to defend himself (Gabdulhakov 2018, 317). In addition, digital vigilantism often leads to mistaken identity, which entails disproportionate harm and stigmatisation of the innocent (Dekker and Meijer 2020).

Thus, digital vigilantism not only threatens the safety of individual citizens but also undermines legal certainty in society, contributing to a decrease in trust in state institutions.

To prevent the negative consequences of digital vigilantism, its legal regulation is necessary. Kyrgyzstan already has a number of laws that cover aspects of digital violence to some extent, including the Law on Protection from Unreliable (False) Information (2021), the Law on Personal Information (2008), as well as certain articles of the Criminal Code and the Code of Offenses.

However, there are still significant gaps in the current legislation. In particular, there are no legal acts regarding such phenomena as digital vigilantism, doxing, online shaming, trolling and cyberbullying. This creates legal uncertainty and makes it difficult to classify such actions as offenses.

The problem is compounded by the fact that existing regulations are often applied not against the actual initiators of digital crime, but against journalists and activists. For example, in 2023, the Ministry of Culture, citing the Law on Unreliable Information, demanded that Internet providers block access to the website of the independent media “Kloop” (Radio Svoboda 2023).

An additional challenge remains the underestimation of digital violence as a form of offense due to its virtual nature, as well as the limited competence of law enforcement agencies in combating online violence (Ombudsman Kyrgyzstan 2023).

This state of legislation and the work of government agencies creates a favourable environment for the unpunished spread of digital lynching, which requires comprehensive measures against this problem.

Policy change

Coordinated work in the legislative and institutional areas is needed to combat digital violence.

The initial task is legislative reform. Despite the existence of general norms covering defamation and violation of privacy, a clearer definition of concepts related to digital vigilantism and legal response mechanisms is needed. At the moment, no definition of the concept of digital lynching has been found in the jurisdictions of different countries in order to implement their practice. However, it is possible to adopt laws on issues related to digital violence, such as doxing, online shaming and harassment.

For example, since 2024, doxing has been a punishable offense in the Netherlands, which creates more conditions for combating this phenomenon. As a result, victims can report doxing, investigations are launched immediately, perpetrators are easier to prosecute, and data is deleted faster (Council of Europe 2024).

Along with the development of the legislative framework, a key area is the development of the institutional capacity of government agencies involved in the fight against cybercrime. To this end, it is necessary to develop and implement a training strategy for law enforcement officers that covers the skills of preventing and investigating digital violence. International practices can serve as a useful guide in this process, in particular, the Europol Training Competency Framework, which defines competencies in the field of digital investigations, as well as the joint guide of the Council of Europe and INTERPOL, which contains step-by-step recommendations for building national training strategies (Europol 2024; Council of Europe and INTERPOL 2022).

Key actors

Implementation of the proposed measures requires the involvement of the following actors:

Actor	Role
Parliament of the Kyrgyz Republic	Developing and adopting legislation aimed at defining and criminalising digital violence
Ministry of Digital Development	Coordination of digital policy, development of personal data protection standards
Ministry of Internal Affairs and the Prosecutor General's Office	Improving the qualifications of employees, creating specialised units to combat cybercrime
Judicial authorities	Developing the practice of considering cases of digital violence, taking into account international human rights standards
The Ombudsman Institute and Civil Society	Monitoring of violations, support for victims, and development of human rights response mechanisms

Recommendations

Digital vigilantism poses a growing threat to human rights and the sustainability of the legal system. It undermines trust in institutions, provokes violence and stigmatization of the innocent. In the absence of a timely response, digital vigilantism can turn into a sustainable practice outside the legal framework.

To prevent this threat, Kyrgyzstan needs to:

Adopt specialized legislation regulating digital violence, including doxing, shaming and harassment

Create and implement a national strategy for law enforcement training

Ensure the institutional protection of digital rights and the development of legal response mechanisms.