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Poland - Regional Administrative Court in Warsaw, 7 October 2014, no IV SA/Wa 1074/14

The right to court, which includes the principle of contradictoriness and its essential element – the possibility to get acquainted with the information in possession of the authority or the court  – is not a value overriding other values protected by the national legal order.

Such an understanding is reflected in EU law – Article 13 para 1 of the Returns Directive.

In the opinion of the Court it is not inconsistent with Article 47 of the Charter of Fundamental Rights, bearing in mind Article 52 para. 1.

Disclosing concrete information gathered by a specialised agency, responsible for state security, enables identification of the source of information, so it can pose a threat to other persons or even exclude the possibility of obtaining any further relevant information.

In this situation, taking into account the need to protect state security there are limitations which impact upon the procedural rights of a person. However these are justifiable on account of public interest. 

Date of decision: 07-10-2014
Relevant International and European Legislation: European Union Law,EN - Charter of Fundamental Rights of the European Union,Article 47,Article 52,EN - Returns Directive, Directive 2008/115/EC of 16 December 2008,Article 12,Article 13,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 6
Belgium - Council for Alien Law Litigation, 18 September 2014, No. 129604
Country of applicant: Cameroon

The Aliens Litigation Court has cancelled a judgment by the Secretary of State for Asylum, Migration and for Social Integration, which refuses leave to remain to a Cameroon national with an order of expulsion to Cyprus, the first European State through which the applicant entered.

Date of decision: 18-09-2014
Relevant International and European Legislation: 1.,Article 3
ECtHR - Trabelsi v. Belgium, (Application no. 140/10), 4 September 2014
Country of applicant: Tunisia

The ECtHR has unanimously held that Belgium, in extraditing a Tunisian national to the US, where he was under prosecution on charges linked to Al-Qaeda, without any regard to the interim Rule 39 measure issued by the Court suspending the extradition, had violated both Article 3 and Article 34 (right to individual applications)of the ECHR.

Date of decision: 04-09-2014
Relevant International and European Legislation: Article 3,Article 4,Article 5,Article 13,Article 34
Slovakia – Supreme Court, 29/7/2014, M.L.J. in Ministry of Interior of the Slovak Republic, Presidium of the Police Force, Foreign and Border Police, Directorate of the Foreign and Border Police Sobrance, Department of the Border Control Podhoroď, 1Sža/21
Country of applicant: Afghanistan

The Respondent erred in detaining the Applicant under § 88a (1)(a) point 1 of Act No 404/2011 Coll. on the residence of aliens and amending certain other Acts in proceedings relating to administrative expulsion to the Ukraine, despite being aware of the Applicant’s intention to apply for asylum. The Respondent also incorrectly assessed whether Ukraine is a safe third country as he failed to take into account recent information on the current situation in Ukraine. Moreover, in assessing the risk of absconding, the Respondent asked improper questions. As such the Respondent's conduct violates principles of good governance.

Date of decision: 29-07-2014
Relevant International and European Legislation: 1951 Refugee Convention,Art 32,Art 31,EN - Charter of Fundamental Rights of the European Union,Article 6,EN - Returns Directive, Directive 2008/115/EC of 16 December 2008,Recital (9),Article 15,1.,4.,EN - Dublin II Regulation, Council Regulation (EC) No 343/2003 of 18 February 2003,Article 7,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 5,Art 5.1,Art 5.4
UK - Detention Action (applicant) v Secretary of State for the Home Department (defendant) and Equality Human Rights Commission (intervener) [2014] EWHC 2245

Ouseley J in the High Court held although the practice and policy of the Secretary of State in operating the Detained Fast Track System (DFT) was not unlawful in its terms, there was room for improvement. The screening process must not only focus on the suitability of a claim for fast-tracking, but it must also consider the impact that a tight timetable and detention may have on the fair presentation of a claim. In addition, lawyers must be allocated to applicants earlier to allow for meaningful instructions to be given and to allow for vulnerable status to be highlighted. Falling short of unlawfulness, the system carried too high a risk that unfair determinations would be made against applicants. 

Date of decision: 09-07-2014
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,EN - Charter of Fundamental Rights of the European Union,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 5
ECtHR - Georgia v Russia, Application no 13255/07, 3 July 2014
Country of applicant: Georgia

The ECtHR holds that Russia is in violation of Article 5 ECHR and of Article 4 of Protocol 4 through the implementation of an unlawful administrative practice against a large number of Georgian nationals as a means of identifying them. This led to the arrest, detention and collective expulsion of 4634 Georgians from the Russian Federation and further violations of Articles 3 and 13 of the Convention.

Date of decision: 03-07-2014
Relevant International and European Legislation: 1951 Refugee Convention,ECHR (Frist Protocol),Art 2,European Union Law,International Law,Council of Europe Instruments,EN - Charter of Fundamental Rights of the European Union,Article 4,Article 19,Article 21,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,Recital (25),Recital (38),Recital (42),Recital (50),Article 20,Article 25,Article 36,EN - Returns Directive, Directive 2008/115/EC of 16 December 2008,Article 13,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 2,Article 3,Article 5,Article 8,Article 13,Article 14,Article 18,Article 35,Article 38,EN - Dublin III Regulation, Council Regulation (EC) No. 604/2013 of 26 June 2013 (recast Dublin II Regulation),Article 27,ECHR (Fourth Protocol),Art 4,Art 1
ECtHR - Mohammadi v Austria, Application No. 71932/12
Country of applicant: Afghanistan

The Dublin transfer of the applicant to Hungary will not violate Article 3 of the Convention. 

Date of decision: 03-07-2014
Relevant International and European Legislation: 2.,Article 5,Article 6,Article 7,Article 8,Article 9,Article 10,Article 11,Article 12,Article 13,Article 14,Article 17,Article 18,Article 19,Article 3
ECtHR - A. A. M. v. Sweden, Application No. 68519/10
Country of applicant: Iraq

The European Court of Human Rights has ruled that, due to the availability of internal protection, Sweden can deport an asylum seeker back to Iraq provided that he is not returned to parts of Iraq situated outside the Kurdistan Region.

Date of decision: 03-07-2014
Relevant International and European Legislation: Article 3,Article 8
ECtHR - De los Santos and de la Cruz v. Greece, Applications Nos. 2134/12 and 2161/12
Country of applicant: Dominican Republic
Keywords: Detention

A violation of Article 3 of the Convention in respect of the applicants’ detention conditions in the Thessaloniki department for illegal immigration pending removal. 

Date of decision: 26-06-2014
Relevant International and European Legislation: Article 3
ECtHR – M.E. v. Sweden, Application No. 71398/12
Country of applicant: Libya

ECtHR majority rules that the temporary return of a homosexual man from Sweden to Libya would not violate Article 3 as short term concealment of sexual orientation would be tolerable in order to reduce risk of persecution. 

Date of decision: 26-06-2014
Relevant International and European Legislation: Article 3,Article 8