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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
ECtHR – Dbouba v. Turkey, Application No. 15916/09, 13 October 2010
Country of applicant: Tunisia
The applicant, a Tunisian national who has been recognised as a refugee by the UNHCR, faced deportation by Turkey to Tunisia, where he risks ill-treatment and the death penalty. He has not had access to an effective remedy with regards to this, nor has he been allowed to challenge the lawfulness of his detention. By virtue of the applicant’s proposed return to Tunisia the Court found a violation of Article 3 ECHR in conjunction with Article 13. The Court also found a violation of articles 5(1), 5(2), 5(4) and 5(5) ECHR.
 
Date of decision: 13-10-2010
ECtHR- D.B. v. Turkey, Application no. 33526/08, 13 October 2010
Country of applicant: Turkey

The European Court of Human Rights (ECtHR) has ruled that Turkey had violated Article 5 para 1 and 4 of the Convention with regards to the applicant’s unlawful detention and lack of remedy to challenge the lawfulness of his deprivation of liberty. Further, it found a violation of Article 34.

Date of decision: 13-10-2010
ECtHR- D.B. v. Turkey, Application no. 33526/08, 13 October 2010
Country of applicant: Iran

The European Court of Human Rights (ECtHR) has ruled that Turkey had violated Article 5 para 1 and 4 of the Convention with regards to the applicant’s unlawful detention and lack of remedy to challenge the lawfulness of his deprivation of liberty. Further, it found a violation of Article 34.

Date of decision: 13-10-2010
ECtHR - M.B. and others v Turkey, Application no. 36009/08, 15 September 2010
Country of applicant: Iran

The applicants, a family of four from Iran, were deported back to Iran from Turkey after having been granted refugee status by the UNHCR. The applicants challenged the lawfulness of their detention, claimed that they were not offered an effective remedy prior to their deportation and that they were at risk of persecution upon their return to Iran. 

Date of decision: 15-09-2010
France - Administrative Tribunal, 29 July 2010, Mr.A., No 1013868/9-1
Country of applicant: Afghanistan

The French authorities shall use the sovereignty clause in the Dublin Regulation, under the judge’s supervision, when the rules that determine responsibility of a member state for the asylum procedure may infringe on international and national rights guaranteed to refugees and applicants for asylum. In this case a transfer order to Hungary, where the applicant had on two occasions been detained in unsuitable conditions, was held to be an unlawful infringement of the applicant’s right to asylum.

Date of decision: 29-07-2010