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Germany – Federal Administrative Court, 24 November 2009, 10 C 24.08
Country of applicant: Russia, Russia (Chechnya)

In an internal armed conflict, war crimes may be committed not only against the civilian population, but also against combatants.

  1. At present, a definition of what constitutes war crimes or crimes against humanity has to be primarily based on the elements of these crimes as determined in the International Criminal Court (ICC) Statute.
  2. In an internal armed conflict, war crimes may be committed not only against the civilian population, but also against combatants.
  3. As a rule, acts by combatants which form part of combat operations in an internal armed conflict, and which do not constitute crimes against peace, war crimes or crimes against humanity (under Section 3 II (1) (1) of the German Asylum Procedure Act), will also not constitute the exclusion ground of a serious non-political crime.
Date of decision: 24-11-2009
Finland - Supreme Administrative Court, 3 April 2008, KHO:2008:21
Country of applicant: Afghanistan

This case concerned the exclusion from refugee status of a Taliban informer. The Supreme Administrative Court did not apply the exclusion clause in Art IF(b) (corresponding to § 87 paragraph 2 of the Finnish Aliens Act).The Court held that exclusion clauses must be interpreted in the narrowest possible manner.

Date of decision: 03-04-2008
Germany - High Administrative Court Niedersachsen, 2 May 2007, 11 LA 367/05
Country of applicant: Turkey

Exclusion from refugee status under Section 60 (8) (2) Residence Act/Art. 12.2 and Art. 12.3 of the Qualification Directive is only justified if the person concerned poses an ongoing threat.

Date of decision: 27-05-2007
Germany - High Administrative Court Nordrhein-Westfalen, 27 March 2007, 8 A 4728/05.A
Country of applicant: Turkey

Exclusion from refugee status on the grounds of serious non-political crimes is only permissible if the applicant still poses a threat. The Court found that an applicant from Turkey, who had been subject to past persecution, was not sufficiently safe from renewed persecution if returned.

Date of decision: 27-03-2007