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CJEU - C-472/13, Andre Lawrence Shepherd v Bundesrepublik Deutschland
Country of applicant: United States

The judgment concerns the status of military deserters under the Qualification Directive (2004/83/EC) and the definition to be accorded to persecutory acts following on from a refusal to perform military service. Whilst the definition of military service is to include support staff the CJEU has held that there must be a sufficient link between the asylum seeker’s actions and the preparation or eventual commission of war crimes.  

The individual must establish with sufficient plausibility that his unit is highly likely to commit war crimes and that there exists a body of evidence capable of credibly establishing that the specific military service will commit war crimes. Moreover, desertion is the only way to avoid participation in war crimes and disproportionate and discriminatory acts should be assessed in light of a State’s domestic prerogatives.  

Date of decision: 26-02-2015
Relevant International and European Legislation: Art 1A (2),Art 1,Art 4.3,Art 10,Recital 6,Recital 1,Recital 3,Art 13,Art 12.2,Art 12.3,Art 9.2 (b),Art 9.2 (c),Recital 16,Art 2 (c),Art 9.2 (e),Article 15
Greece - The Council of State, 4 July 2012, 2450/2012
Country of applicant: Pakistan

This case concerned the conditions under which a refusal to perform military service for conscientious reasons may justify granting refugee status. The Minister for Public Order did not give reasons for deviating from the competent Committee's recommendation, nor did he find it to be ambiguous or to have any other legal defect, while he could have referred the case back to that body for reassessment. The application for annulment is granted.

Date of decision: 04-07-2012
Relevant International and European Legislation: Art 1A,Art 9.2 (b),Art 9.2 (c),Art 2 (c),Art 9.2 (e)