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ECtHR - Tatar v. Switzerland, Application no. 65692/12, 14 April 2015
Country of applicant: Turkey

The case examined the allegations of the applicant that his proposed expulsion to Turkey would place him at risk of inhuman and degrading treatment and would jeopardize his physical and health integrity.

The Court found no violation of the articles 2 and 3 of the Convention and held the claimed violations of articles 6 and 8 to be unfounded.

Date of decision: 14-04-2015
Relevant International and European Legislation: 1951 Refugee Convention,Art 1,Art 32,Art 33,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 2,Article 3,Article 6,Article 8,Art 6.1
France - Council of State, 10 April 2015, M. A., No. 372864
Country of applicant: Sri Lanka

The French National Asylum Court (the “CNDA”)  must assess whether or not the applicant should be granted refugee status or, failing that, subsidiary protection,taking into account all the factual on the basis of the circumstances which are known to the CNDA when it rules. In order to assess the accuracy of the facts reported by an applicant, the CNDA must take into account all evidence presented by an applicant in support of his application. In particular, when an applicant produces circumstantial evidence relating to the alleged risks that he is likely to face if he returns to his country of origin, the CNDA must – after assessing the credibility of such evidence and analysing it in light of the reported facts – assess the potential risks  which the facts reveal and, as the case may be, indicate the elements that led the CNDA to consider these risks to be not sufficiently serious. 

Date of decision: 10-04-2015
Relevant International and European Legislation: 1951 Refugee Convention,Art 1A (2),International Law,Council of Europe Instruments,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3
Spain - Provincial Court of Melilla, 7 April 2015, Spanish Public Prosecutor (Ministerio Fiscal) v. Federación Andalucía Acoge, SOS Racismo del Estado Español, Asociación pro derechos de la infancia-Prodein, Asociación coordinadora de barrios (437/2014)

The physical border around the enclave of Melilla is conformed by two fences and the intermediate zone created between them. The Spanish military police (Guardia Civil) considers that until a migrant has not overcome the second fence he or she has not entered into Spanish territory and therefore, Spanish law, including the Organic Act 4/2000 on the Rights and Liberties of Foreigners in Spain and their Social Integration (“Aliens Act”), does not apply to a migrant apprehended in the intermediate zone.

The Court ruled that, although this interpretation may violate international law, since there is no clear definition under Spanish law of where the border is located, the direct refusal of migrants who have reached the intermediate zone, does not constitute an administrative prevarication offence. 

Date of decision: 07-04-2015
Relevant International and European Legislation: 1951 Refugee Convention,European Union Law,International Law,Council of Europe Instruments,EN - Charter of Fundamental Rights of the European Union,EN - Dublin II Regulation, Council Regulation (EC) No 343/2003 of 18 February 2003,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Treaty on the Functioning of the European Union 2010/C 83/01
France - National Asylum Court, 24 March 2015, Decision No. 10012810
Country of applicant: Nigeria

The case is a referral back to the CNDA from the Council of State in no. 350661 where the Council had found the CNDA to have erred in law in a previous appeal  (no. 10012810) by finding that Nigerian women, who were victims of human trafficking networks and who had actively sought to escape the network, constituted a social group within the meaning of the 1951 Refugee Convention. The CNDA found that victims of trafficking from the Edo State do, indeed, share a common background and distinct identity which falls within the definition of a particular social group. The applicant was given refugee status.

Date of decision: 24-03-2015
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 9.2,Art 9,Art 10,European Union Law,International Law,Council of Europe Instruments,Art 2 (d),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 15
Hungary - Metropolitan Court of Public Administration and Labour, 6 March 2015, 7.K.34.513/2014/11
Country of applicant: Egypt

This case examines the refusal to grant international protection status to a physically disabled, single Egyptian woman. The OIN failed to provide clear, detailed reasoning why the Applicant did not meet the legal conditions to acquire subsidiary protection status in Hungary.

The Metropolitan Court of Public Administration and Labour granted subsidiary protection status to the Applicant and concluded that based on cumulative grounds the Applicant would be subject to torture, cruel, inhuman or degrading treatment or punishment if she returned to Egypt.

Date of decision: 06-03-2015
Relevant International and European Legislation: 1951 Refugee Convention,Art 33,European Union Law,International Law,Council of Europe Instruments,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,Article 24,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011,Article 2,Article 4,Article 6,Article 7,Article 18,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Article 21
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
Spain - The Supreme Court of Spain (Tribunal Supremo), 23 February 2015, Legal Appeal (Recurso de Casación), Case No. 2944/2014
Country of applicant: Kazakhstan

The Supreme Court held that the National High Court of Spain (Audiencia Nacional) erred in annulling the General Deputy Director of Asylum’s decision to reject the Appellant’s request for international protection because the National High Court of Spain failed to consider the substance of the Appellant’s request for asylum.

Date of decision: 23-02-2015
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 4,European Union Law,International Law,Council of Europe Instruments,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 2,Article 3
Spain - Spanish Supreme Court (Tribunal Supremo), Cassation Appeal, 23 February 2015 (Appeal No. 2944/2014)
Country of applicant: Kazakhstan

The Supreme Court declared that the National High Court erred when annulling the decision of the General Sub-Directorate for Asylum (Ministry of Interior) to reject the Appellant’s request for international protection. The National High Court annulled the decision but did not consider the Appellant’s core claim: the request for international protection.

As the National High Court was in possession of all necessary facts required to decide on the substance of the request by the Appellant for international protection, it should have been able to determine as such. As a result, the Supreme Court upheld the appeal.

Date of decision: 23-02-2015
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 1A (2),Art 4,Art 33,European Union Law,International Law,Council of Europe Instruments,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 2,Article 3
Greece - Supreme Court, 20 February 2015, 186/2015
Country of applicant: Turkey

A Turkish National, who has been granted political asylum by the Swiss Government, was detained in Greece. After a decision made by the Greek authorities, his extradition to Turkey was ordered. This decision was quashed by the Greek Supreme Court. 

Date of decision: 20-02-2015
Relevant International and European Legislation: 1951 Refugee Convention,EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,European Union Law,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011
Switzerland – Federal Administrative Court, 18. February 2015, D-5553/2013
Country of applicant: Syria

Even after the introduction of Art. 3 (3) AsylG, the previous legal practice with regard to persons who justify their asylum application by refusing military service or desertion in their home country continues to be valid. Accordingly, a conscientious objection to military service or desertion cannot establish refugee status on its own, only if it is associated with persecution within the meaning of Art. 3 para. 1 AsylG.

Date of decision: 18-02-2015
Relevant International and European Legislation: Art 9,Art 1,Art 9.1,Art 33,Article 3