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ECtHR - R.U. v. Greece, Application No. 2237/08
Country of applicant: Turkey

The case concerned detention and detention conditions in Greece for a Turkish asylum seeker of Kurdish origin, who had been tortured in Turkey, and the conduct of the asylum procedure.

Date of decision: 07-09-2011
UK - High Court, 11 August 2011, Elayathamby, R (on the application of) v Secretary of State for the Home Department [2011] EWHC 2182 (Admin)
Country of applicant: Sri Lanka

The Administrative Court considered the removal of a Sri Lankan from the UK to Cyprus under the Dublin Regulation. The applicant had been recognised under UNHCR’s mandate as being a refugee in Malaysia but had subsequently travelled via Thailand, Syria and Cyprus to the UK. The Court found that there was no legitimate expectation under the UK’s Mandate Refugee policy to consider his claim in the UK. Further, applying the principles in MSS v Belgium and Greece and KRS v UK, it found that the evidence was insufficient to establish that he faced a risk of onward refoulement from Cyprus to Sri Lanka or that detention conditions or living conditions in Cyprus should prevent his removal. 

Date of decision: 11-08-2011
ECtHR - Rahimi v. Greece, Application No. 8687/08
Country of applicant: Afghanistan

Inadequate care and unlawful detention of an unaccompanied minor seeking asylum: the case concerned the conditions in which a minor from Afghanistan, who had entered Greece illegally, was held in the Pagani adult detention centre on the island of Lesbos.

Date of decision: 05-07-2011
Netherlands - Council of State, 4 July 2011, 201103855/1/V2

Partly as a result of his detention, the foreigner's financial resources are limited. The obligation to pay €227.00 in court fees for the processing of an appeal therefore constitutes a major breach of the right to access to justice guaranteed under Article 47 of the Charter of Fundamental Rights of the European Union, amongst other provisions. The appeal should therefore have been examined on its merits despite the court fees not being paid.

Date of decision: 04-07-2011
Austria - Constitutional Court, 28 June 2011, B4/11
Country of applicant: Guinea

Legality of detention in the event of imminent deportation to Greece, if the detention was imposed before the judgment by the ECtHR in the case M.S.S. v Belgium and Greece (application no. 30696/09) and there is an enforceable expulsion decision.

Date of decision: 28-06-2011
CJEU - C-61/11, PPU El Dridi
Country of applicant: Unknown
Keywords: Detention, Return

The Directive on the return of illegal immigrants precludes national rules imposing a prison term on an illegally staying third-country national who does not comply with an order to leave the national territory.

Date of decision: 28-04-2011
Belgium - Council for Alien Litigation, 17 February 2011, No. 56203
Country of applicant: Russia

With this judgment, the General Assembly of CALL is trying to bring its case law in line with the M.S.S. judgment of the ECtHR.

The CALL set the conditions under which an appeal for suspension against an enforceable decision (an order to leave the territory) has automatic suspensive effect.

After a prima facie examination (in extreme urgency), the CALL decided that the applicant in this casehas a reasonable ground of appeal on the basis of Article 3 of the ECHR, as he gave sufficient indications of the concrete problems he was experiencing in Poland. The CALL derived from this a duty of investigation on the part of the Aliens Office. This was sufficient for the CALL, furthermore, to provisionally suspend enforcement of an agreement with Poland to take back the applicant, pending the processing of an appeal for revocation.

Date of decision: 17-02-2011
ECtHR - M.S.S. v Belgium and Greece [GC], Application No. 30696/09
Country of applicant: Afghanistan

This case examined the compatibility of the Dublin II Regulation with the European Convention on Human Rights regarding transfers to Greece under the Dublin II Regulation. The Court found that there was a violation of Article 3 ECHR by the Greece Government because of the applicant’s conditions of detention, violation of Article 3 ECHR by Greece concerning the applicant’s living conditions in Greece, violation of Article 13 taken in conjunction with Article 3 ECHR against Greece because of the deficiencies in the asylum procedure followed in the applicant’s case and the risk of his expulsion to Afghanistan without any serious examination of the merits of his asylum application and without any access to an effective remedy. The Court also found in relation to Belgium that there was a violation of Article 3 by sending the applicant back to Greece and exposing him to risks linked to the deficiencies in the asylum procedure in that State, also held against Belgium a violation of Article 3 for sending him to Greece and exposing him to detention and living conditions there that were in breach of that ECHR article. The Court also found a violation of Article 13 ECHR taking in conjunction with Article 3 ECHR against Belgium.

Date of decision: 21-01-2011
France – Council of State, 19 November 2010, Mrs. E. v Minister for the Interior, No 344372
Country of applicant: Russia

The failure of an asylum applicant to appear with her children (systematically or repeatedly) when summoned in relation to a transfer order under the Dublin Regulation is considered as absconding and results in the extension of the transfer deadline to 18 months. In this case, the applicant never appeared with her children despite receiving several notifications and, according to the Council of State, she was aware that the presence of her children was crucial in order to proceed with her transfer.

Date of decision: 19-11-2010
ECtHR - Louled Massoud v. Malta, Application No. 24340/08
Country of applicant: Algeria

Unlawful detention of an Algerian citizen in Malta for more than 18 months.

Date of decision: 27-10-2010