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ECtHR Khaksar v. the United Kingdom (no. 2654/18)
Country of applicant: Afghanistan

The exhaustion of domestic remedies is a prerequisite for the admissibility of applications lodged with the ECtHR under Article 35 ECHR. Removal of individuals suffering from severe medical problems may not be considered inhumane in the meaning of Article 3 ECHR, when suitable treatment exists in the country of origin.  

 

Date of decision: 03-04-2018
Relevant International and European Legislation: Art 1A (2),Article 14,Article 3,Article 8,Article 35,Article 2,Article 6,Article 9,Article 10
Austria – Higher Administrative Court, March 21st 2018, Ra 2017/18/0474
Country of applicant: Afghanistan

The judicial examination of whether subsidiary protection shall be approved requires a thorough assessment of the individual case. This applies in particular for especially vulnerable persons.

Date of decision: 21-03-2018
Relevant International and European Legislation: Article 2,Article 3,Article 21
Court of The Hague, 19 March 2018, NL 17.11921
Country of applicant: Iraq

In assessing the credibility of a sexual orientation-related claim, personal circumstances have to be taken into account. That a person is not able to elaborate on his awareness and acceptance of his sexual orientation, is not sufficient to conclude that the applicant’s story lacks credibility, when the personal circumstances that explain this inability are considered credible.

Date of decision: 19-03-2018
Relevant International and European Legislation: Art 10,Art 4,Art 13
Court of The Hague, 19 March 2018, NL 17.11921
Country of applicant: Iraq

In assessing the credibility of a sexual orientation-related claim, personal circumstances have to be taken into account. That a person is not able to elaborate on his awareness and acceptance of his sexual orientation, is not sufficient to conclude that the applicant’s story lacks credibility, when the personal circumstances that explain this inability are considered credible.

Date of decision: 19-03-2018
Relevant International and European Legislation: Article 4,Article 10,Article 13
France – Council of State, 16 March 2018, N° 418019
Country of applicant: Afghanistan

The Council of State grants the appeal lodged by the Minister of the Interior, who asked for the annulment of the order issued by the administrative tribunal’s relief judge. The latter had suspended not only the execution of the decision refusing to register M. A…’s asylum application, but also the execution regarding his transfer, by ruling ultra petita. After qualifying M. A…’s non-attendance to the repeated notifications sent for the purpose of his transfer as being intentional and systematic, the Council of State concludes in this case that no violation was found against M. A…’s fundamental liberty of the right to asylum. 

Date of decision: 16-03-2018
Relevant International and European Legislation: European Union Law,EN - Dublin III Regulation, Council Regulation (EC) No. 604/2013 of 26 June 2013 (recast Dublin II Regulation),Article 29
Portugal: Adnan v. Immigration and Borders Service, National Director, 15 March 2018 No. 2163/17.7BELSB
Country of applicant: Syria

The Court found that due to the inexistence of the connection requirement between the applicant and the State of Ecuador, the latter cannot be considered a “safe third country” in light of Article 2 n.º1 point r) item i) of the Law 27/2008. Nonetheless, the international protection request should be rejected on the basis that Egypt is considered to be the first country of asylum, excluding the possibility of granting international protection under Article 19º-A n. º1 points c) and d) of the Law 26/14.

Date of decision: 15-03-2018
Relevant International and European Legislation: Recital (44),Article 38
ECtHR – A.E.A. v Greece, Application no. 39034/12, 15 March 2018
Country of applicant: Sudan

The possibility to lodge an asylum application in practice is a prerequisite for the effective protection of those in need of international protection. If access to the asylum procedure is not guaranteed by the national authorities, asylum applicants cannot benefit from the guarantees afforded to those under the asylum procedure, leaving them subject to detention at any time. The length of time in which it took for the applicant to lodge his asylum application violated his rights under Article 13 read in conjunction with Article 3 ECHR.

Date of decision: 15-03-2018
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 6,European Union Law,Council of Europe Instruments,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3,Article 13,Article 35,Article 41
France - Administrative Court of Appeal of Lyon, 13 March 2018, nos 17LY02181 – 17LY02184
Country of applicant: Afghanistan

An internal armed conflict, characterised by armed clashes, prevails throughout the whole territory of Afghanistan. The situation in the Kabul region and the city itself constitutes indiscriminate violence resulting from this internal armed conflict.

Transferring a family to Finland under the Dublin Regulation where their asylum application and subsequent appeals have been rejected is unlawful on account of the humanitarian and security situation in Afghanistan. 

Date of decision: 13-03-2018
Relevant International and European Legislation: 1951 Refugee Convention,Art 33,European Union Law,International Law,Council of Europe Instruments,EN - Charter of Fundamental Rights of the European Union,Article 1,Article 4,Article 19,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3,EN - Dublin III Regulation, Council Regulation (EC) No. 604/2013 of 26 June 2013 (recast Dublin II Regulation),Article 13,Article 17,Article 18,Article 19
France – Court of Appeal of Nîmes, 9 March 2018, n° 18/01183
Country of applicant: Tunisia
Keywords: Detention, Return

The Judge of the liberty and detention of the Nîmes Court of Appeal declared irregular the procedure during which the applicant, who couldn’t read, was not properly informed by the police of his rights to apply for asylum and his right to free access to the telephone at the detention centre.

Date of decision: 09-03-2018
Relevant International and European Legislation: EN - Returns Directive, Directive 2008/115/EC of 16 December 2008
Sweden - Migration Court of Appeal, 5 March 2018, UM2630-17
Country of applicant: Eritrea

The Appellant and the appellant’s  children were applying for leave to remain in Sweden due to affiliation with their husband and father respectively who had been granted a permanent right of residency in Sweden as a refugee - despite them not being able to prove their identities. Due to the appellant’s lack of relevant documentation for her and the children,  the court had to consider the circumstances in which a  person can be granted alleviation of evidentiary burden in terms of proving their identity.

The Migration Court of Appeal granted the appeal and held that the appellant and the children would be granted an alleviation of evidentiary burden. It further referred the case back to the Swedish Migration Agency who would have to complete a DNA-test aimed at establishing the kinship of the family and subsequently try the case again. 

Date of decision: 05-03-2018
Relevant International and European Legislation: European Union Law,EN - Family Reunification Directive, Directive 2003/86/EC of 22 September 2003,Article 11