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Slovenia - Supreme Court of the Republic of Slovenia, 28 December 2011, I Up 732/2011
Country of applicant: Afghanistan

The Plaintiff’s previous experience does not lead to the  conclusion that the Plaintiff is afraid of persecution (in the event that he was returned) based on race, religion, national identity, membership of a particular social group or a certain political belief, as his fear is based on the possible consequences of retribution merely because he fled. According to the judgment of the Supreme Court the fact that he fled from the Taliban does not make him a “member of a particular social group” on the basis of which his refugee status could be recognised.

Because the Plaintiff did not mention his current political conviction and his current anti-Taliban religious belief when applying for international protection he is not entitled to a refugee sur place status. 

Date of decision: 28-12-2011
Relevant International and European Legislation: Art 15,Art 10,Art 5
Austria – Asylum Court, 28 December 2011, S7 423.367 to 370-1/2011/2E
Country of applicant: Russia (Chechnya)

This was an appeal against the decision that Poland was responsible for the asylum application of a three-month-old boy with a serious medical condition. The Austrian Federal Asylum Office did not consider the applicant’s medical condition appropriately and therefore risked violating Art 3 ECHR.

Date of decision: 28-12-2011
Relevant International and European Legislation: Article 17,2.,Article 3
Finland - Supreme Administrative Court, 27 December 2011, KHO:2011:114
Country of applicant: Iran

A Muslim asylum seeker and his/her spouse joined Jehovah’s Witnesses in Finland – a religious community.  In their home country, Iran, converting away from Islam can mean a death sentence.  The Administrative Court should not have been allowed to deny the application without an oral hearing in which further information could have been given regarding the Applicants’ conversion to Christianity and the consequences thereof in their home country.

Date of decision: 27-12-2011
Relevant International and European Legislation: Art 5,Art 4.3
CJEU - C-411-10 and C-493-10, Joined cases of N.S. v United Kingdom and M.E. v Ireland
Country of applicant: Afghanistan, Iran, Nigeria

This case concerned the concept of ‘safe country’ within the Dublin system and respect for fundamental rights of asylum seekers. The Court held that EU law prevents the application of a conclusive presumption that Member States observe all the fundamental rights of the European Union. Art. 4 Charter must be interpreted as meaning that the Member States may not transfer an asylum seeker to the Member State responsible within the meaning of the Regulation where they cannot be unaware that systemic deficiencies in the asylum procedure and in the reception conditions of asylum seekers in that Member State amount to substantial grounds for believing that the asylum seeker would face a real risk of being subjected to inhuman or degrading treatment within the meaning of the provision. Once it is impossible to transfer the asylum seeker to the responsible Member State then subject to the sovereignty clause the State can check if another Member State is responsible by examining further criteria under the Regulation. This should not take an unreasonable amount of time and if necessary then the Member State concerned must examine the asylum application. 

Date of decision: 21-12-2011
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 8,Art 7,Art 9,Art 18,Art 23,Art 24,Art 12,Art 17,Art 15,Art 10,Art 5,Art 4,Art 6,Art 16,Recital 10,Art 39,Art 11,Art 13,Art 14,Art 26,Art 28,Art 29,Art 31,Art 21,Art 32,Art 33,Art 19,Art 36,Art 20,Art 30,Art 25,Article 1,Article 4,Article 18,Art 19.2,Article 47,Art 20.1,Art 22,Art 33,Art 34,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,Recital (5),Recital (15),Article 13,Article 17,Article 18,Article 19,EN - Convention for the Protection of Human Rights and Fundamental Freedoms
Austria - Administrative Court, 15 December 2011, 2011/21/0237
Country of applicant: Kosovo

Contrary to the wording of the corresponding Austrian legislation, an entry ban of at least 18 months which must be issued in every case together with a ban on readmission is not compatible with the Returns Directive without a prior examination on a case-by-case basis. 

Date of decision: 15-12-2011
Relevant International and European Legislation: Article 7,Article 6,Article 7,Article 11,Article 8
Austria - Constitutional Court, 15 December 2011, U760/11
Country of applicant: Armenia

After six and a half years of single asylum proceedings, the Applicants, a family with three children who were well-integrated in Austria, , were expelled by the Asylum Court to Armenia. The Constitutional Court revoked this decision on the grounds of a violation of Art 8 of the European Convention on Human Rights. The reasons for this were primarily that the integration of the children was given insufficient weight.

Date of decision: 15-12-2011
Relevant International and European Legislation: Article 7,Article 8
Austria- Constitutional Court, 13 December 2011, U1907/10
Country of applicant: Russia

As a result of six convictions owing to trivial offences against property, subsidiary protection was withdrawn from the Applicant, as he would represent a danger to the general public. The Constitutional Court revoked this decision as unconstitutional: the Asylum Court had not interpreted the corresponding national stipulation in accordance with the Directives as the crimes committed were not of the seriousness required in Art 17 Qualification Directive.

Date of decision: 13-12-2011
Relevant International and European Legislation: Art 17,Art 1F,Art 19,Art 6,Art 13,Article 2,Article 3
Ireland - High Court, 13 December, J.K. (Uganda) v Minister for Justice and Equality, [2011] IEHC 473
Country of applicant: Uganda

The applicant was not permitted to raise a new ground of claim based on her asserted homosexuality, when she had had numerous opportunities to raise this ground of claim earlier.  The applicant was however granted leave to apply for judicial review, upon the Judge noting a factual error that had tainted the State’s earlier credibility assessment. 

Date of decision: 13-12-2011
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 32,Art 34,Art 33
UK - Court of Appeal, 13 December 2011, HM (Iraq) and RM (Iraq) v Secretary of State for the Home Department [2011] EWCA Civ 1536
Country of applicant: Iraq

The Court quashed a country guidance decision on the application of Art 15(c) of the Qualification Directive in Iraq because the Tribunal had not considered what was necessary to ensure that it heard proper argument in a case designed to give binding guidance for other applicants.

Date of decision: 13-12-2011
Relevant International and European Legislation: Art 15 (c),Art 15
Germany - High Administrative Court of Sachsen, 12 December 2011, A 3 A 292/10
Country of applicant: Turkey

Exclusion from refugee protection on the grounds of "serious non-political crime" or of "acts against the purposes and principles of the United Nations", cannot solely be based on the fact that an applicant has been a supporter or a member of an organisation which has been classified as terrorist. There must be serious reasons to justify the assumption that the applicant was personally involved in the commission of such crimes.

Date of decision: 12-12-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 4.4,Art 12.2,Art 12.3