National case summaries

Slovakia - R. v Ministry of the Interior of the Slovak Republic, 22 June 2010, 1Sža/51/2010
Country of applicant: Turkey

The threat of punishment for an act that is regarded as a crime in the country of origin is not a reason for granting asylum.

Date of decision: 22-06-2010
Belgium – Council for Alien Law Litigation, 18 June 2010, Nr. 45.095, 45.096, 45.098
Country of applicant: Bosnia and Herzegovina
This case concerned the status of family members. The CALL held that Art 23 of the Qualification Directive, which has no direct effect, does not create a right for the family member of a beneficiary of refugee or subsidiary protection status to benefit from the same status, and reminds Member States of the necessity to take into account the personal legal status of the family member (e.g. different nationality). Where a child has parents with two different types of status and the nationality of the child cannot be established, then the child should be given the status that is most beneficial to him/her.
Date of decision: 18-06-2010
Finland - Supreme Administrative Court, 18 June 2010, 2776/1/09
Country of applicant: Russia

The decision of the Administrative Court to refuse the applicant an oral hearing was overturned. The SAC held the Administrative Court did not show the Qualification Directive (which was implemented during the proceedings) had been applied and that the Administrative Court failed to take into consideration that as an asylum seeker the applicant had limited possibilities of supporting his claim by submitting written evidence only.

Date of decision: 18-06-2010
UK - Court of Appeal, 18 June 2010, FA (Iraq) v Secretary of State for the Home Department [2010] EWCA Civ 696
Country of applicant: Iraq

In UK domestic law, if a person has made a claim for asylum but his claim has been rejected by the Secretary of State, but he has been given leave to enter or remain in the United Kingdom for over a year, the person can appeal to the Tribunal on the grounds that he or she is a refugee in order to ‘upgrade’ his or her status. The Court held that the general principle of equivalence in EU Law requires that the appeal right against the rejection of the claim cannot be restricted to the grounds that the applicant is a refugee but must also allow the applicant to appeal on the grounds that he is entitled to subsidiary protection.

Date of decision: 18-06-2010
France - Council of State, 16 June 2010, Ms. A., n°340250

French legislative provisions concerning the non suspensive effect of the judicial remedy under the accelerated procedure are not manifestly incompatible with the Asylum Procedures Directive and the Reception Conditions Directives.  

Date of decision: 16-06-2010
France - Council of State, 14 June 2010, M. A., n°320630
Country of applicant: Rwanda

Serious reasons have to be established in order to apply the exclusion clause in Article 1F(a) of the 1951 Refugee Convention, i.e. the material and intentional elements specific to the complicity.

Date of decision: 14-06-2010
France - Council of State, 14 June 2010, OFPRA c/ M. A., n°323669
Country of applicant: Afghanistan

The involvement in a State regular police force does not constitute, in itself, the expression of political opinions or the membership of a particular social group.

Date of decision: 14-06-2010
Spain - Supreme Court, 4 June 2010, 2987/2010
Country of applicant: Tunisia

The applicant lodged an appeal before the Supreme Court challenging the decision of the High National Court to refuse granting refugee status. The refusal was founded on the application of an exclusion clause. It was held that the applicant constituted a danger to Spanish security. This decision examined the conditions required to apply this exclusion clause, namely that it has to be determined that there are “reasonable grounds” to believe that such danger exists.

Date of decision: 04-06-2010
Belgium - Council for Alien Law Litigation, 31 May 2010, Nr. 44.471
Country of applicant: Russia (Chechnya)
When it comes to establishing the facts of a case, the Office of the Commissioner General for Refugees and Stateless Persons (CGRS) cannot limit itself to finding that the applicant has not provided any documentary evidence and that its own research was unsuccessful. This would give the false impression that in asylum matters documentary evidence is a primary or even a determining factor.
Date of decision: 31-05-2010
France – Council of State, 28 May 2010, Mr. A. v Minister of Immigration, No 339624
Country of applicant: Congo (DRC)

In this case the Council of State had to determine whether the evidence presented by the applicant in relation to his alleged absence from EU territory for more than 3 months was sufficient to apply Article 4(5) of the Dublin Regulation. The Council held such evidence should include not only proof of absence itself but also proof of the exit and entry dates in relation to the period of absence, which was missing in this case. 

Date of decision: 28-05-2010