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Germany - Administrative Court Berlin, 9 June 2011, 33 K 285.10 A
Country of applicant: Afghanistan

It is in principle possible for men to be persecuted on account of their gender. However, classifying the punishment for extramarital sex in Afghanistan as persecution on account of both membership of the group of men and the group of women would cover the entire society and renders the definition meaningless. Therefore, the applicant was not granted refugee status but his deportation was prohibited under Section 60 (2) of the Residence Act / Art 15 (b) of the Qualification Directive.

Date of decision: 09-06-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 9.2,Art 10.1 (d),Art 10.1 (e),Art 9.3,Art 6 (c),Art 10.2,Art 9.1,Art 2 (c)
Belgium – Council for Alien Law Litigation, 9 June 2011, Nr. 62.867
Country of applicant: Niger
This case concerned the assessment of the risk of being subjected to slavery on return. The CALL held that slavery is sufficiently grave by its nature to constitute persecution. The Court further added that the prohibition of slavery is an absolute and non-derogable right and that slaves can be considered as a particular social group.
Date of decision: 09-06-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 10.1 (d),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 4,Article 15
Germany - High Administrative Court Sachsen-Anhalt, 25 May 2011, 3 L 374/09
Country of applicant: Syria

A stateless Kurd from Syria was not recognised as a refugee. The court held:

  1. The denial of re-entry of stateless Kurds is not to be considered political persecution because a general institutional practice cannot be detected which is aimed against ethnic Kurds in a manner that is relevant to asylum grounds (Art 10 of the Qualification Directive).
  2. Whether the legal practice of Syrian legislation on citizenship and the denial of re-entry are part of a restrictive policy towards Kurds, and support the aims of the State of Syria in respect of its settlement policy, is not important when determining political persecution under Section 60 (1) sentence (5) of the Residence Act in connection with Art. 9 and 10 Qualification Directive.
Date of decision: 25-05-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 15 (c),Art 10,Art 9.3,Art 4.3 (c),Art 9.1,Art 9.1 (a),Art 2 (c),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 15
Netherlands - District Court Haarlem, 25 May 2011, AWB 10/44949
Country of applicant: Iran

Restriction of the right to attend church is an act of persecution and therefore a violation of Art 10 of the Qualification Directive.

Date of decision: 25-05-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 10,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3
Belgium – Council for Alien Law Litigation, 19 May 2011, Nr. 61.832
Country of applicant: Somalia

Refugee status was granted on the basis of a well-founded fear of persecution based on the applicant facing  a second act of Female Genital Mutilation (FGM) on return to Somalia (persecution ground: membership of a particular social group). 

Date of decision: 19-05-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 10.1 (d)
France - CNDA, 29 April 2011, Miss E., n°10012810
Country of applicant: Nigeria

Prostitutes who come from the State of Edo, and who are both victims of human trafficking and anxious to extricate themselves actively from these networks, form a group whose members are, by reason of these two common characteristics which define them, likely to be subjected to persecution within the meaning of Article 1A(2) of the 1951 Refugee Convention, without being able to avail themselves of the protection of the Nigerian authorities. They are members of a particular social group.

Date of decision: 29-04-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 10.1 (d),Art 15,Art 6
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
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 10.1 (d),Art 4.4
France - CNDA, 23 April 2008, Miss N., n°574495
Country of applicant: Nigeria

Women who are subjected to the norms and customary laws of FGM and forced marriage in rural areas in Nigeria cannot avail themselves of the protection of the State authorities, and their attitude is perceived as an infringement by the community members. They therefore form a social group within the meaning of Article 1 A (2) of the 1951 Refugee Convention. Furthermore, the impossibility of marrying another person constitutes an obstacle to leading a normal life in another part of the country and an alternative protection alternative cannot be considered. 

Date of decision: 23-04-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 8,Art 2,Art 7,Art 10.1 (d),Art 6
Germany - Administrative Court of Oldenburg, 13 April 2011, 3 A 2966/09
Country of applicant: Algeria

Refugee status was granted to an Algerian woman who was at risk of forced marriage due to membership of a particular social group.

Date of decision: 13-04-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 8,Art 9,Art 10.1 (d),Art 4.4
Finland - Supreme Administrative Court, 8 April 2011, KHO:2011:1012
Country of applicant: Afghanistan

The Supreme Administrative Court (SAC) returned the case to the Administrative Court for reconsideration based on the applicants' change of circumstance (conversion to Christianity in Finland) which only became apparent during the appeal before the SAC.

Date of decision: 08-04-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 7,Art 5,Art 9.3,Art 10.1 (b),Art 4.3 (d),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3