On his release from exile Tsereteli returned to Georgia and aligned himself with the RSDLP's Georgian branch, later known as the Georgian Mensheviks (the minority faction within the party). He also began working as an editor for his father's former publication, "Kvali" ("კვალი"; "Trace"), writing most of their leading articles. However, in January 1904 he was again arrested, and spent two months in the Metekhi prison in Tiflis; two months later "Kvali" was banned. Tsereteli was allowed to leave Georgia, likely due to the influence of his uncle, so he moved to Berlin to resume his law studies, spending 18 months in Europe. Suffering from a form of haemophilia, Tsereteli became seriously ill in the autumn of 1905, but was unable to quickly return home for rest as the 1905 Revolution broke out in the Russian Empire. It was only in May 1906 that he returned to Georgia.