Case summaries

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Poland - Regional Administrative Court in Warsaw, 21 December 2010, V SA/Wa 383/10
Country of applicant: Russia

This judgment overturned the decision of the Polish Refugee Board on revocation of refugee status. Adoption of state protection within the meaning of the law means that a foreigner benefits from the protection of the state of his nationality, that he is able to avail himself of this protection and that there exists no well-founded fear of persecution. Adoption of state protection means that the foreigner enjoys the genuine protection of his country of origin.

In proceedings on revocation of refugee status, the authority determines whether there are other reasons to justify the foreigner’s fear of persecution.

Date of decision: 21-12-2010
Relevant International and European Legislation: Art 2 (e),Art 37,Art 38,Para 150,Para 151,Art 11.1 (e)
Spain – Supreme Court, 22 October 2010, 1660/2006
Country of applicant: Colombia

This decision concerns an appeal lodged before the Supreme Court against the decision of the High National Court, confirming the Ministry of Interior’s decision to revoke the refugee status of the appellant and her children. This revocation was issued following the voluntary return of the applicant’s husband to Colombia, his country of origin.

Date of decision: 22-10-2010
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 4.3,Art 11.1 (d),Art 37,Art 38,Art 1C (5)
UK - Supreme Court, 12 May 2010, ZN (Afghanistan) (FC) and Others (Appellants) v. Entry Clearance Officer (Karachi) (Respondent) and one other action, [2010] UKSC 21
Country of applicant: Afghanistan

This case concerned the application of the principle of family unity, where the sponsor had been granted asylum and subsequently acquired the nationality of the country of refuge.

Date of decision: 12-05-2010
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 23,Art 11,Art 1F,UNHCR Handbook,Art 1C (3),Chapter VI,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 8
UK - Court of Appeal, 23 April 2010, HH (Somalia) & Others v Secretary of State for the Home Department [2010] EWCA Civ 426
Country of applicant: Somalia

In this case the Court applied the CJEU’s decision in Elgafaji and the UK Court of Appeal’s decision in QD and AH (see separate summary on EDAL) and considered whether UK Immigration Tribunals had jurisdiction to consider Art 15 (c) in cases where removal directions had not been set. The specific issue concerned the risk of indiscriminate violence en route from Mogadishu to a safe area. It further considered and made important obiter comments on the ambit of Art 15 (c).

Date of decision: 23-04-2010
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 15 (c),Art 15 (b),Art 2 (e),Art 8,Art 16,Recital 26,Art 11.1 (e),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 2,Article 3
Finland - Supreme Administrative Court, 12 Dec 2008, KHO:2008:88
Country of applicant: Sudan

The applicant’s refugee status was revoked due to a change in circumstances in the applicant’s country of origin as per section 107 subsection 5 of the Aliens’ Act, where the applicant’s individual need of protection was assessed in light of the notable and established social change in Sudan.

Date of decision: 12-12-2008
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 11,Art 14,Art 1C (5),UNHCR Handbook
Germany - Administrative Court Stuttgart, 29 June 2006, A 11 K 10841
Country of applicant: Iran

This case concerned the application of Art 10.1 (d) of the Qualification Directive, as applied to lesbians from Iran. It was found that the "particular social group", described as homosexual (lesbian) women, has a distinct identity in Iran, because they are perceived as being different by the surrounding society (Art. 10.1 (d) (1) of the Qualification Directive).

Further, that there is a high likelihood that a homosexual relationship between women would be persecuted when detected, because it constitutes a breach of a cultural norm, even worse than among homosexual (gay) men.

Date of decision: 29-06-2006
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 8,Art 7,Art 9,Art 10.1 (d),Art 12,Art 10,Art 6,Art 11,Art 9.2 (c),Art 9.1 (a),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 15