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Czech Republic - Supreme Administrative Court, 23 March 2011, J.S.A. v. Ministry of Interior, 6 Azs 40/2010-70
Country of applicant: Cuba

The case concerned an appeal against a decision of the Ministry of Interior (MOI) to refuse a claim for subsidiary protection status on the grounds that the applicant was excluded as a result of his activities, which were considered ‘contrary to the purposes and principles of the United Nations.’ The appeal was successful, the Supreme Administrative Court (SAC) held that exclusion clauses must be interpreted restrictively, that there must be ‘serious grounds to believe’ such acts were carried out and notwithstanding the exclusion clause, non refoulement obligations under Art 3 of the ECHR apply.

Date of decision: 23-03-2011
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,1951 Refugee Convention,Art 15 (c),Art 12,Art 12.2 (c),Art 17,Art 1F(c),Art 32,Recital 22,Art 17.2,Art 17.1 (c),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3
Belgium – Council for Alien Law Litigation, 22 July 2010, Nr. 46.578
Country of applicant: Iraq

The CALL ruled that the Qualification Directive, with reference to the grounds for revocation, clearly shows a difference between the various types of protection and that there is no indication that the Belgian legislator wished to deviate from this. Subsidiary protection can be revoked on the basis of a “serious crime” committed after protection was granted.

Date of decision: 22-07-2010
Relevant International and European Legislation: EN - Qualification Directive, Directive 2004/83/EC of 29 April 2004,Art 2 (e),Art 17.2,Art 17.1,Art 19.3 (a),Art 19.3 (b),EN - Convention for the Protection of Human Rights and Fundamental Freedoms,Article 3