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Austria – Asylum Court, 24 September 2010, S5 317.551-2/2010/2E
Country of applicant: Russia (Chechnya)

After the applicant absconded the time frame for a deportation was extended by 18 months and, therefore, Poland’s original acceptance was still valid at the time of the second application. Art 7 Dublin II Regulation is not applicable because the applicant’s family life was established after his first application for asylum. There is no violation of Art 8 ECHR because the applicant’s family life was formed at a moment when the applicant did not know whether he would be able to maintain it.

Date of decision: 24-09-2010
Sweden - Migration Court of Appeal, 6 September 2010, UM 8098-09
Country of applicant: Turkey

The right to family life can outweigh the ‘state responsibility’ criteria in the Dublin II Regulation. The Court held that the application for asylum should be processed in Sweden, in order to secure the right to family and private life (Art 8 of the European Convention on Human Rights), despite the fact that another State was responsible under the Dublin II Regulation.

Date of decision: 06-09-2010
ECtHR - Mengesha Kimfe v. Switzerland, no. 24404/05, 29 July 2010
Country of applicant: Ethiopia

The applicant and her husband were both Ethiopian nationals who had their asylum applications in Switzerland definitively rejected, but were unable to return. The Swiss authorities refused the applicant’s requests to be transferred to her husband’s canton, leading to approximately 5 years separation.

The Court found a violation of their Article 8 right to respect for family life, as the measure had not been necessary in a democratic society.

Date of decision: 29-07-2010
ECtHR - Agraw v. Switzerland, no. 3295/06, 29 July 2010
Country of applicant: Ethiopia

The applicant and her husband were both Ethiopian nationals who had their asylum applications in Switzerland definitively rejected, but were unable to return. The Swiss authorities refused the applicant’s requests to be transferred to her husband’s canton, leading to approximately 5 years separation.

The Court found a violation of their Article 8 right to respect for family life, as the measure had not been necessary in a democratic society. 

Date of decision: 29-07-2010
Austria – Asylum Court, 29 July 2010, S3 403.581-3/2010/2E
Country of applicant: Russia (Chechnya)

In this case, the Austrian Asylum Court held the decision of the Federal Asylum Office not to grant refugee status to the applicant’s child was a violation of Austrian asylum law since the child’s father had been granted refugee status. The Court also held a separation of the newborn child from its mother violates Art 8 ECHR and, therefore, the applicant’s asylum application has to be admitted to the procedure on the merits.

Date of decision: 29-07-2010
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
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
Sweden - Migration Court, 20 May 2010, UM 4942-10
Country of applicant: Armenia

An Armenian opposition politician was considered a political refugee by the Migration Court of Appeal. Both the Migration Board and the Migration Court believed the applicant's political commitment and account of events. The Board considered, however, that the Armenian authorities' actions were not unreasonable and dismissed the application.

The Migration Court stated the fact that the applicant was not imprisoned for long periods did not imply that the arrests and ill-treatment that took place could be considered as acceptable measures by the authorities. Nor could the actions of the authorities be considered as reasonable or acceptable.  The applicant was considered to be the victim of persecution that was rooted in his political belief.

Date of decision: 20-05-2010
UK - Supreme Court, 12 May 2010, ZN (Afghanistan) (FC) and Others (Appellants) v. Entry Clearance Officer (Karachi) (Respondent) and one other action, [2010] UKSC 21
Country of applicant: Afghanistan

This case concerned the application of the principle of family unity, where the sponsor had been granted asylum and subsequently acquired the nationality of the country of refuge.

Date of decision: 12-05-2010
Sweden - Migration Court of Appeal, 11 May 2010, UM 6397-09
Country of applicant: Iraq

When assessing the availibility of an internal protection alternative the possibilities for the applicant to live together with his/her family in the country of origin should be taken into account. This applies even if the applicant’s family are not seeking asylum in Sweden. However, first a need for international protection needs to be established.

Date of decision: 11-05-2010