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Slovakia - F.CH. v Ministry of Interior of the Slovak Republic, 26 May 2009, 1Sža/12/2009
Country of applicant: Cameroon

Insofar as the Migration Office relied on the Applicant’s claim that he was a member of the SCNC and recognised this ground for the purposes of the subsidiary protection procedure without disputing the claim of membership of the SCNC, and insofar as the deliberations on the possibility of serious harm resulting from this membership led to the granting of subsidiary protection, it seems illogical that the Migration Office disputed these grounds in the asylum procedure because of the unreliability of the Applicant’s claim regarding membership, concluded that the Applicant had failed to demonstrate a well-founded fear of persecution on this ground, and thus refused to grant him asylum on this basis. 

Date of decision: 26-05-2009
Belgium – Council of State, 26 May 2009, Nr. 193.523
Country of applicant: Russia
The Council of State ruled that in support of an application for subsidiary protection a mere reference to the general situation in the country of origin is insufficient, and that the applicant needs to make a link between that general situation and his/her personal situation, even if no proof of an individual threat is required. The applicant’s account was found to be implausible regarding her recent stay/residence and as a result the applicant made the establishment of such a link impossible.
Date of decision: 26-05-2009
Netherlands - AJDCoS, 22 April 2009 , 200809034/1/V2
Country of applicant: Gambia

The case concerns whether or not the accelerated procedure used in the applicant’s claim was consistent with Art 23.4 of the Asylum Procedures Directive which allows for an accelerated procedure. It was found that the accelerated procedure was consistent with the Asylum Procedures Directive because the applicant was found not to be credible.

Date of decision: 22-04-2009
Netherlands - District Court Amsterdam, 7 April 2009, AWB 08/05416
Country of applicant: Sierra Leone

This case concerned the insufficient sourcing of evidence relied upon by the decision maker in dismissing the applicant’s claim for protection. It was found to be a violation of Art 16.1 of the Asylum Procedures Directive where the decision was insufficiently sourced in the applicant’s file. Further that this violation is not remedied by making specific references to those sources before the court. 

Date of decision: 07-04-2009
Belgium – Council of State, 18 March 2009, Nr. 191.585
Country of applicant: Iraq
This case considered whether or not an applicant should be granted a right of appeal, where he had committed fraud in his asylum claim. The Council of State ruled that the general principle of law “fraus omnia corrumpit” (fraud corrupts everything) does not preclude the fact that an applicant has a lawful interest in order to appeal a negative decision of the Office of the Commissioner General for Refugees and Stateless Persons (CGRS) with the Council for Alien Law Litigation (CALL), unless it transpired that the appeal itself was tainted by fraud.
Date of decision: 18-03-2009
Spain – Supreme Court, 16 February 2009, 6894/2005
Country of applicant: Colombia

The Applicant appealed before the Supreme Court against the decision of the High National Court to reject his application for refugee status. The applicant, his wife and their children claimed asylum alleging persecution on the basis of membership of a particular social group. Their claim was rejected at first instance on the grounds that the facts presented lacked credibility and the applicants could avail themselves of an internal protection alternative. On appeal before the Supreme Court, the decision of the High National Court was revoked and refugee status was granted.

Date of decision: 16-02-2009
Ireland - High Court, 23 January 2009, V.O. v Minister for Justice, Equality and Law Reform & Anor, [2009] IEHC 21
Country of applicant: Nigeria

This concerned whether the Office of the Refugee Applications Commissioner (ORAC) were required to make an assessment of subsidiary protection, and whether ORAC were obliged to examine country of origin information in every case. The court found that ORAC were not required to make a subsidiary protection assessment. The Court held that ORAC were not obliged to examine country of origin information in every case.

Date of decision: 23-01-2009
Hungary – Metropolitan Court, 16 January 2009, L.M.N. v. Office of Immigration and Nationality, 17.K.32.826/2007/15
Country of applicant: Kenya

The Kenyan applicant was a potential victim of female genital mutilation (FGM) and she faced forced marriage upon return. The Court stated that even if there was a risk of persecution in case of a return to the country of origin, the applicant could reasonably be expected to relocate internally as it was feasible in the circumstances.

Date of decision: 16-01-2009
Netherlands - District Court Almelo, 28 November 2008, AWB 08/39512
Country of applicant: Colombia

This case concerned whether or not a proper assessment of an internal protection alternative had been carried out. It was found that careful research had not been done regarding the question of whether a part of Colombia meets the internal protection criteria as set out in Art 8.1 of the Qualification Directive, taken together with Art 8.2 of the Qualification Directive.

Date of decision: 28-11-2008
Belgium - Council for Alien Law Litigation, 6 November 2008, Nr. 18.419
Country of applicant: Albania

This case considered whether or not a “family” could constitute a particular social group under the Refugee Convention. The applicant, whose family was implicated in a vendetta, had a well-founded fear of persecution on the basis of her membership of the social group that is her family. It was held by the CALL that a family could constitute a particular social group. 

Date of decision: 06-11-2008