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ECtHR – M.N. and others v. Belgium, Application no. 3599/18, 5 May 2020
Country of applicant: Syria

Not all cases with an international element can establish jurisdiction under the Convention; an assessment of exceptional circumstances on the basis of the specific facts of each case is required.

The applicants do not have any connecting links with Belgium and their sole presence in the premises of the Belgian Embassy in Lebanon cannot establish jurisdiction, as they were never under the de facto control of Belgian diplomatic or consular agents. Jurisdiction under Article 1 ECHR cannot be established solely on the basis of an administrative procedure initiated by private individuals outside the territory of the chosen state, without them having any connection with that State, nor any treaty obligation compelling them to choose that state.

Date of decision: 05-05-2020
Relevant International and European Legislation: Art 33.1,Article 18,Article 3,Art 51.1,Art 52.3,Article 1,Article 3,Article 6,Article 13,Article 3
ECtHR - N.D. and N.T. v. Spain [GC], nos. 8675/15 and 8697/15, 13 February 2020
Country of applicant: Ivory Coast, Mali

The Court found no violation of the Convention given that the applicants would have had access to a genuine and effective possibility of submitting arguments against their expulsion had  they entered lawfully into Spain – they did not have any “cogent reasons” for not using the border procedures available at designated entry points. As such, the lack of an individualised procedure for their removal was the consequence of their own conduct.

Date of decision: 13-02-2020
Relevant International and European Legislation: Art 1,Art 3,Art 32,Art 33,Art 31,Art 4,Art 16,Art 22,Article 4,Article 18,Article 19,Art 19.1,Art 19.2,Article 47,Article 6,Article 7,Article 8,Article 9,Article 10,Article 1,Article 2,Article 4,Article 5,Article 8,Article 12,Article 13,Art 33.2,Article 1,Article 3,Article 13,Article 13,Article 2,Article 4,Article 14,Article 21,Art 4,Art. 3,Article 67,Article 78
ECtHR – Z.A. and Others v. Russia, Applications nos. 61411/15, 61420/15, 61427/15 and 3028/16, 21 November 2019
Country of applicant: Iraq, Palestinian Territory, Somalia, Syria

Confinement of asylum applicants in an airport transit zone is contrary to Art. 5 § 1 (f) in the absence of any domestic legal basis for the applicants’ deprivation of liberty.

Confinement of asylum seekers left to their own devices in airport transit zones under the control of border authorities, without unimpeded access to shower or cooking facilities, outdoor exercise and medical or social assistance amount to degrading and inhuman conditions under Art. 3 ECHR if protracted for a long time. 

Date of decision: 21-11-2019
Relevant International and European Legislation: Art 33,Art 31,Article 15,5.,6.,Article 3,Article 5,Article 36,Art 5.1,Art 5.1 (f),Article 10,Article 18
Portugal: Administrative Litigation Section of the Central Administrative Court, 24/10/2019, proc. nº 397/19.9BELSB
Country of applicant: Congo (DRC)

The applicant claims that the original Court neither made a detailed analysis of the applicant's political action – that gave rise to the persecution and, consequently, the asylum application – nor of the subsidiary protection application.

The recursive claim was declared unfounded by the Central Court, which found that there was no evidence of persecution or systematic human rights violations in the country of origin.

Date of decision: 24-10-2019
Relevant International and European Legislation: Art 33
Greece - 7th Appeals Committee, 28 June 2019
Country of applicant: Venezuela

The political, humanitarian and economic crisis in Venezuela can justify subsidiary protection status if the individual’s return to the country of origin, would cause serious harm, characterized by the level of seriousness required to be considered as inhuman and degrading treatment.

Date of decision: 28-06-2019
Relevant International and European Legislation: Art 1A (2),Art 33,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,Article 3,Article 15,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011,UN Convention against Torture,Art. 3
Switzerland: Federal Administrative Court (BVG), 12.06.2019, BVGE 3078/2019
Country of applicant: Syria

The State Secretariat for Migration (SEM) must carry out an individualised examination to determine whether there are substantial grounds for believing that the asylum procedure of the Member State where the applicant shall be transferred to has systemic weaknesses that would entail a risk of inhuman treatment or chain deportation.

Date of decision: 12-06-2019
Relevant International and European Legislation: EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Art 33,Article 4,EN - Recast Asylum Procedures Directive 2013/32/EU of the European Parliament and of the Council,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,EN - Dublin II Regulation, Council Regulation (EC) No 343/2003 of 18 February 2003,Article 3,Article 3,Article 5,Article 7,Article 8,Article 15,Article 17,Article 18,Article 20,Article 21,Article 22,Article 29,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013,Art. 3
ECtHR - M.A. and Others v. Lithuania (no. 59793/17), 11 December 2018
Country of applicant: Russia

The ECtHR ruled that failure to allow a Russian family with five children to submit asylum applications on the Lithuanian border and their removal to Belarus amounted to a violation of Article 3 ECHR. 

Date of decision: 11-12-2018
Relevant International and European Legislation: 1951 Refugee Convention,EN - Asylum Procedures Directive, Council Directive 2005/85/EC of 1 December 2005,Recital 6,Art 1,Art 33,Art 31,European Union Law,International Law,Recital 8,EN - Charter of Fundamental Rights of the European Union,Article 18,Article 19,EN - Recast Qualification Directive, Directive 2011/95/EU of 13 December 2011,Article 2,Article 15,Article 21
CJEU – Case C 175/17 X, 26 September 2018
Country of applicant: Iraq

The CJEU ruled on  the scope of the right to an effective remedy provided for in Article 39 of the Asylum Procedures Directive and in Article 13 of the Returns Directive.

Date of decision: 26-09-2018
Relevant International and European Legislation: Art 3,Art 39,Recital 5,Art 33,Recital 8,Article 18,Article 19,Art 19.2,Article 47,Recital (2),Recital (4),Recital (24),Article 2,Article 3,Article 12,Article 13,Article 3,Article 13
CJEU – Case C 180/17, X and Y, 26 September 2018
Country of applicant: Russia

The CJEU ruled on  the scope of the right to an effective remedy provided for in Article 46 of the (Recast) Asylum Procedures Directive and in Article 13 of the Returns Directive.

Date of decision: 26-09-2018
Relevant International and European Legislation: Art 33,Article 18,Article 19,Art 19.2,Article 47,Recital (12),Recital (60),Article 3,Article 46,Recital (2),Recital (4),Recital (24),Article 2,Article 3,Article 12,Article 13,Article 3,Article 13
N.T.P. and others v. France (No. 68862/13), 24 August 2018
Country of applicant: Congo (DRC)

The Court examines the individuals’ circumstances and finds that the appointment with the French authorities to register and assess their asylum cases within a three-month period, coupled with the possibility for the applicants to stay in a foster home at night, access education, healthcare and meals provided by organisations during the day, cannot amount to treatment prohibited under the Convention.

Date of decision: 24-08-2018
Relevant International and European Legislation: Art 33,EN - Reception Conditions Directive, Directive 2003/9/EC of 27 January 2003,EN - Recast Reception Conditions Directive, Directive 2013/33/EU of 26 June 2013