Case summaries

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Greece - 11th Appeals Committee, Decision no. 17627/18, 9 September 2019
Country of applicant: Unknown

The interview of an unaccompanied minor, conducted without any legal representation, violated domestic and international provisions regarding the right to a hearing and the best interest of the child.

Date of decision: 09-09-2019
Relevant International and European Legislation: Article 14,UN Convention on the Rights of the Child
Greece - 7th Appeals Committee, 28 June 2019
Country of applicant: Venezuela

The political, humanitarian and economic crisis in Venezuela can justify subsidiary protection status if the individual’s return to the country of origin, would cause serious harm, characterized by the level of seriousness required to be considered as inhuman and degrading treatment.

Date of decision: 28-06-2019
Relevant International and European Legislation: Art 1A (2),Art 33,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,Article 3,Article 15,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011,UN Convention against Torture,Art. 3
Belgium - Council for Alien Law Litigation, June 19th 2019, X. v. Commissioner-General for Refugees and Stateless Persons, n° 222 826
Country of applicant: Guinea

A Guinean woman who has been forced into marriage at a young age and subsequently harassed into marrying her late husband’s brother, is a refugee under article 1, section A §2 of the Geneva Convention. She risks being persecuted by reason of her membership in the social group of women, and considering the regular violation of women’s rights occuring in Guinea.

Date of decision: 19-06-2019
Relevant International and European Legislation: Art 1A (2),Art 1F,Article 24,Art 24.2,Article 5,Article 46,Article 4,Article 23
ECtHR - Sh.D. and others v. Greece, Austria, Croatia, Hungary, Northern Macedonia, Serbia and Slovenia (no. 141165/16)
Country of applicant: Afghanistan

Conditions in police stations do not justify prolonged detention, while the child’s extreme vulnerability should prevail over irregular status with necessary measures adopted to protect them. Domestic authorities had not done all that could reasonably expected to fulfil their obligation in light of their vulnerability.

The authorities violated Article 5 by automatically applying the protective custody regime, without considering any alternatives to detention or the requirement under EU law to avoid the detention of children.

Date of decision: 13-06-2019
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,EN - Returns Directive, Directive 2008/115/EC of 16 December 2008,Article 3,Article 5,Art 5.1,UN Convention on the Rights of the Child
Greece - Piraeus Administrative Court of Appeal, Decision A401/2019, 12 June 2019
Country of applicant: Ghana
Date of decision: 12-06-2019
Relevant International and European Legislation: Art 1A (2),Article 3,Article 15,Recital (30),Article 10
Switzerland: Federal Administrative Court (BVG), 12.06.2019, BVGE 3078/2019
Country of applicant: Syria

The State Secretariat for Migration (SEM) must carry out an individualised examination to determine whether there are substantial grounds for believing that the asylum procedure of the Member State where the applicant shall be transferred to has systemic weaknesses that would entail a risk of inhuman treatment or chain deportation.

Date of decision: 12-06-2019
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 33,Article 4,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,EN - Dublin II Regulation, Council Regulation (EC) No 343/2003 of 18 February 2003,Article 3,Article 3,Article 5,Article 7,Article 8,Article 15,Article 17,Article 18,Article 20,Article 21,Article 22,Article 29,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Art. 3
AS (Afghanistan) v Secretary of State for the Home Department, 2019
Country of applicant: Afghanistan

The Court of Appeal set aside the Upper Tribunal’s Country Guidance on internal relocation to Kabul, on the basis that it had made a factual error, wrongly stating that civilian causalities amounted to less than 0.001 per cent, rather than less than 0.1 per cent, of the population of Kabul. However, it did dismiss AS’s ground of appeal, which concerned whether internal relocation would be unreasonable.

Date of decision: 24-05-2019
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,UNHCR Handbook
Italy - Tribunal of Trapani - Office of the Judge for Preliminary Investigations (Piero Grillo)
Country of applicant: Ghana, Sudan

The Court recognised self-defence in a case where migrants were charged with assault against a police officer following their rescue at sea and their impending return to Libya. Their well-founded fear of return to Libya provided the basis for their defence of duress. 

Date of decision: 23-05-2019
Relevant International and European Legislation: 1951 Refugee Convention,Article 4,Article 18,Article 19,Article 3,UN Convention against Torture,Treaty on the Functioning of the European Union 2010/C 83/01
Belgium – X. v. Commissioner General for Refugees and Stateless Persons, No. 220.190, 24th April 2019
Country of applicant: Morocco

LGBT individuals who have left Morocco can be granted refugee status as the socially and legally hostile environment towards LGBT individuals in this country can justify fear of persecution based on their membership to a particular group. A cautious assessment of the consequences of a return to the country of origin and an extensive benefit of the doubt are advised in the review of asylum applications of Moroccan nationals identifying as LGBT.

Date of decision: 24-04-2019
Relevant International and European Legislation: Art 1A (2),Article 10
WA (Pakistan) v The Secretary of State for the Home Department, 2019
Country of applicant: Pakistan
This case dealt with the issue of the whether the guidance of MN and others Pakistan CG [2012] was still accurate in terms of asylum protection due to failing to ask the question of why an individual would act in a discreet way in their country of origin. This question draws the distinction between concealment of faith due to fear of persecution or simply due to social norms or personal preference.
 
WA sought to challenge the correctness of the guidance in MN and others Pakistan CG [2012] in that it failed to properly reflect the judgement of HJ (Iran) test of asking why an individual would act in a particular way to avoid persecutory harm in their country of origin. The unanimous judgement allowed the appeal and remitted the case back for a hearing. 
 
Date of decision: 06-03-2019
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,EN - Charter of Fundamental Rights of the European Union,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011