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ECtHR – R.R. and others v. Hungary, Application no. 36037/17, 2 March 2021
Country of applicant: Afghanistan, Iran

The absence of food provision raised an issue of Article 3 in respect of the first applicant, given his state of total dependency on the Hungarian government during his stay at the Röszke transit zone. The physical conditions of the container in which the family stayed in, the unsuitable facilities for children, irregularities in the provision of medical services, and the prolonged stay in the area amounted to a violation of Article 3 in respect of the applicant mother and the children.

The family’s stay at the Röszke transit zone amounted to deprivation of liberty due to, inter alia, the lack of any domestic legal provisions fixing the maximum duration of the applicants’ stay, the excessive duration of the applicants’ stay and the conditions in the transit zone. Their deprivation of liberty was unlawful under Article 5 (1), as there was no strictly defined statutory basis for the applicants’ detention and no formal decision complete with reasons for detention had been issued by the Hungarian authorities.

Article 5 (4) was also violated because he applicants did not have avenue in which the lawfulness of their detention could have been decided promptly by a court.

Date of decision: 02-03-2021
Relevant International and European Legislation: Article 43,Article 8,Article 11,Article 17,Article 19,Article 20,Article 21,Article 22,Article 23,Article 25,UN Convention on the Rights of the Child
Germany – Administrative Court Leipzig (VG), 22 April 2020, 3 L 204/20.A
Country of applicant: Cameroon

An asylum seeker is entitled to request the temporary termination of his or her stay in an accommodation centre and to seek alternative accommodation if compliance with the distancing rules of the Saxon Corona Protection Ordinance is not possible in the centre.

Date of decision: 22-04-2020
Relevant International and European Legislation: Article 17,Article 18,Article 22
CJEU – C-233/18 Haqbin, 12 November 2019
Country of applicant: Afghanistan
A sanction imposed in response of serious breaches of the rules of the accommodation centre or of seriously violent behaviour on behalf of an applicant for international protection cannot include withdrawal of material reception conditions relating to housing, food or clothing, even if it is temporary. Authorities should take into particular consideration any such sanction in cases of vulnerable applicants and unaccompanied minors.
Date of decision: 12-11-2019
Relevant International and European Legislation: Article 1,Article 24,Recital (35),Article 2,Article 8,Article 17,Article 20,Article 21,Article 22,Article 23,Article 24
Germany – Federal Constitutional Court, 29 August 2017, 2 BvR 863/17
Country of applicant: Syria

The right to be heard entails the obligation of the court to take note of the arguments put forward by the parties and to take these arguments into consideration when taking its decision. While this does not require the court to explicitly address every single fact put forward by the parties, the grounds of the decision have to refer to the essential issues raised by such facts.

In case of a single mother and her four minor children facing deportation to a country where beneficiaries of international protection had to live under difficult conditions, these personal circumstances of the applicants are of key importance to the legal evaluation. Independently of the question, whether deportations to Bulgaria were, in light of the current conditions, generally permissible, the provisions of Art. 21 et seqq. of the Reception Conditions Directive clearly stipulated that the concerns of families with children had to be given particular consideration.

Consequently, under such circumstances a court was required to specifically set out why it assumed that the family would be guaranteed suitable accommodation that excluded the possibility of health risks and met the needs of a family with children. Otherwise, the decision amounts to an infringement of the applicant’s right to be heard under Art. 103 (1) of the Basic Law.

Date of decision: 29-08-2017
Relevant International and European Legislation: European Union Law,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Article 21,Article 22,Article 23,Article 24,Article 25,Article 26,Article 27,Article 28,Article 29,Article 30,Article 31,Article 32,Article 33,Article 34
UK - R (on the application of SG) v Secretary of State for the Home Department, also known as R (on the application of K) v Secretary of State for the Home Department, 22 June 2017
Country of applicant: Burundi

The reduction in the financial allowance available to child dependants of asylum seekers was not contrary to the requirement that the best interests of the child be a primary consideration in all actions concerning children.

Date of decision: 22-06-2017
Relevant International and European Legislation: European Union Law,International Law,Council of Europe Instruments,EN - Charter of Fundamental Rights of the European Union,Article 1,Article 18,Article 21,Article 24,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,Recital (5),Recital (7),Article 1,Article 13,Article 17,Article 18,Article 24,2.,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 8,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Recital (9),Recital (11),Recital (24),Recital (35),Article 1,Article 17,Article 21,Article 22,Article 23,Article 29,UN Convention on the Rights of the Child
Netherlands - Court of The Hague, 16 October 2015, AWB 15/11534
Country of applicant: Ukraine

There is a real risk that, due to overcrowded accommodation, Hungary can no longer receive returning Dublin claimants. Because of inadequate shelter, the claimant and her two minor children may be subjected to accommodation conditions which contravene Article 3 of the European Convention on Human Rights. Before the return of a vulnerable Dublin claimant occurs, Hungary must first be asked to provide guarantees of adequate shelter. 

Date of decision: 16-10-2015
Relevant International and European Legislation: European Union Law,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,Article 28,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,Article 17,EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3,EN - Dublin III Regulation, Council Regulation (EC) No. 604/2013 of 26 June 2013 (recast Dublin II Regulation),Article 3,Article 18,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Article 21,Article 22