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France - CNDA, 29 July 2011, Miss O., n°10020534
Country of applicant: Nigeria

Young Nigerian women, especially those coming from the region of Benin City (State of Edo), who were forced to prostitute themselves in Europe in a transnational network of human trafficking, and who managed to extricate themselves from this network and to stop this forced activity, should not be seen as members of a particular social group in Nigeria. However, they face inhuman or degrading treatment in case of return to their country of origin and should therefore be granted subsidiary protection.

Date of decision: 29-07-2011
Belgium – Council for Alien Law Litigation, 29 April 2011, Nr. 60.622
Country of applicant: Guinea
The CALL held that the examination of credibility should not overshadow the actual question of whether the applicant has reasons to fear persecution. In this case, refugee status was granted on the basis of a well-founded fear of persecution, by way of a forced marriage and a second excision (Female Genital Mutilation (FGM)).
Date of decision: 29-04-2011
Belgium – Council for Alien Law Litigation, 24 June 2010, Nr. 45.395
Country of applicant: Somalia
The Council for Alien Law Litigation (CALL) held in a general assembly decision that the applicant’s opposition to the Female Genital Mutilation (FGM) of her daughter should be taken as the expression of a political opinion. Further, that when assessing the nationality of the applicant it is important to take into account their specific profile.
Date of decision: 24-06-2010
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
UK - House of Lords, 18 October 2006, Fornah v. Secretary of State for the Home Department (linked with Secretary of State for the Home Department v. K) [2006] UKHL 46
Country of applicant: Sierra Leone

The case concerned a woman who feared return to Sierra Leone because she would face gender specific persecution in the form of Female Genital Mutilation (FGM).  The issue was whether she was entitled to recognition as a refugee because she feared persecution on account of her membership of a particular social group.  Her appeal was allowed on the basis that women in Sierra Leone and, alternatively, uninitiated women who had not been subjected to FGM in Sierra Leone, were particular social groups.

Date of decision: 18-10-2006