ELENA Weekly Legal Update - 19 September 2014
View this email in your browser

19 September 2014

Summary

 
European Court of Human Rights

European Court of Human Rights


F.H. v. Greece (no. 78456/11) [Article 3, 5 and 13], 31st July 2014

In a case which concerned an Iranian national, the European Court of Human Rights (ECtHR) has held that the conditions of various detention centres in Greece, where the applicant was placed, along with the living conditions after his release, constituted degrading treatment and thus a violation of Article 3 (prohibition of torture or inhuman or degrading treatment or punishment) of the European Convention on Human Rights (ECHR). Furthermore, Article 13 (right to an effective remedy) was further breached since the applicant had been given no effective remedy by which to complain of his detention conditions. However, the Court refused to accede to F.H’s submission that Article 5 (right to liberty and security) had also been breached.
 
Upon arrival in Greece in 2010, F.H. was arrested, ordered to return to Iran and held at Feres detention centre. Whilst applying for asylum, F.H was transferred to Venna detention centre. The asylum application was later rejected by the Greek authorities, upon which F.H. lodged an appeal. He was released pending the examination of the appeal, where he subsequently lived as a homeless person in Athens.

Based on an unofficial ECRE translation.
 
Read the ECtHR press release and the original judgment (in French).

Back to top

Tatishvili v. Greece (no. 26452/11) [Article 3 and 5], 31st July 2014

The ECtHR has held that the living conditions in both the premises of the Thessaloniki immigration police station and the Attica immigration department (Petrou Ralli detention centre) in Greece amounted to degrading treatment, thus triggering a breach of Article 3 (prohibition of torture or inhuman or degrading treatment or punishment) of the ECHR. However, the ECtHR ruled that Greece had not breached Mr. Tatishvili’s rights to liberty and security (Article 5 para 1) nor a meaningful or effective remedy with which to challenge the lawfulness of his detention (Article 5 para 4.)
 
The applicant, a Georgian national, born in 1970, arrived in Greece with a two-month visitor’s permit. Mr Tatishvili applied for a residence permit, however, this was later refused due to suspected forgery. He was, subsequently, ordered to leave Greece within thirty days. Arrested in 2010 for failing to leave Greek territory within the deadline, Mr Tatishvili was taken into custody and held at the Thessaloniki immigration police premises. Upon lodging an asylum application and its later rejection, Mr Tatishvili was transferred to the Attica immigration department and later released from these premises in 2011.

Based on an unofficial ECRE translation.
 
Read the press ECtHR press release and the original judgment (in French).

Back to top

 M.V. and M.T. v. France (no. 17897/09) [Article 3 and 13], 4th September 2014

The ECtHR has ruled that to send a couple back to their native country, the Russian Federation, would constitute a violation of Article 3. In light of their family connections, notably an Uncle who had participated in the Chechen rebellion, previous attacks and threats on their persons, and the general situation both previously and in present day Chechnya, the Court held that their return would run a real risk of inhumane treatment by the Russian authorities contrary to Article 3. The Court, however, declined to accept the applicant’s submission that removal to Russia would amount to an Article 13 read in conjunction with Article 3 violation.
 
The applicants lodged an asylum application in France in 2008 having fled Russia out of fear of their safety after several violent encounters with men supposedly affiliated with the current President of Chechnya. Upon arrival in France, the Maine and Loire prefecture rejected the couple’s application stating that they had committed fraud due to the 'unreadability’ of their finger prints in the EURODAC system [12]. Following a second examination and appeal to the National Court of Asylum, M.V and M.T’s asylum applications were both rejected principally because the submitted declarations, files and alleged help given to the Uncle, were insufficient to amount to a finding of inhumane treatment if returned [16]. 

Based on an unofficial ECRE translation.

Read the original judgment (in French).

Back to top

Trabelsi v. Belgium (no. 140/10) [Article 3, 6, 8, 34 and Article 4 of Protocol No. 7], 4th September 2014 

The ECtHR Chamber has unanimously held that Belgium, in extraditing a Tunisian national to the US, without any regard to the interim Rule 39 measure issued by the Court suspending the extradition, has violated both Article 3 and Article 34 (right to individual applications) of the ECHR. The Court dismissed the complaint under Article 3, regarding conditions of detention in Belgium, however, as the applicant had not exhausted his domestic remedies. Furthermore, the court rejected the complaints brought under Article 6 § 1 (right to a fair trial) as being incompatible with the provisions of the Convention, as well as the complaints under Article 8 (right to respect for private and family life) and Article 4 of Protocol No. 7 (right not to be tried or punished twice) as being manifestly ill-founded.
 
Mr. Trabelsi, a Tunisian national, currently incarcerated in the US was sentenced in 2003 by the Brussels Regional Court to ten years’ imprisonment for having attempted to blow up a Belgian military base and having instigated a criminal conspiracy. During this time, Mr. Trabelsi submitted an asylum application in Belgium, which was dismissed in 2009. In 2008, four charges against Mr. Trabelsi of Al-Qaeda-inspired acts of terrorism were transmitted in an arrest warrant by the US authorities to the Belgian authorities. These acts were liable to a sentence of life imprisonment and a fifteen-year term. Acceding to the request of the US authorities on several conditions including the non-enforcement of the death penalty, the non-extradition to a third country, and a possibility of commutation of a life sentence, a Belgian ministerial decree allowing the extradition to the US government was adopted in 2011. Subsequently, Mr. Trabelsi lodged a request with the ECtHR for the indication of an interim measure pursuant to Rule 39 of the Rules of Court with a view to suspending his extradition. The court acceded to the request and notified the Belgian Government that it should not extradite Mr. Trabelsi to the US. Regardless of this, the extradition to the US by the Belgian authorities went ahead in 2013.
 
Article 3
 
Argumentation by the applicant concerned the sentencing that the US was liable to impose upon Mr. Trabelisi for his imputed actions, notably a maximum life prison sentence which was irreducible de facto, with no prospect of ever being released.  With regards to this contention, the Court underlined that the imposition of a sentence of life imprisonment on an adult offender was not, in itself, prohibited by any Article of the Convention, provided that it was not disproportionate. However, the Court confirmed that compatibility with Article 3 required that a sentence should not be irreducible de jure and de facto. Thus, and aligning itself with the Grand Chamber in Kafkaris v. Cyprus,( no. 21906/04), the Chamber assessed whether a life prisoner could be said to have any “prospect of release” and whether national law afforded the “possibility of review” of a life sentence with a view to its commutation, remission, termination or the conditional release of the prisoner [113]. In the present circumstances the Court held that there had been no concrete assurance that Mr. Trabelsi would be spared an irreducible life sentence. Furthermore, despite possibilities to reduce the sentence, the Court reiterated its judgment in Othman (Abu Qatada) v. UK (no. 8139/09)  by stating that no procedure amounting to a mechanism for reviewing such sentences for the purposes of Article 3 was apparent in US legislation [135]. Thus, the life imprisonment to which Mr. Trabelsi might be sentenced could not be described as reducible, meaning that his extradition to the United States had amounted to a violation of Article 3 [138].
 
Article 34
 
In an explicit condemnation of Belgium’s breach of the Rule 39 interim measure, the Court, secondly, highlighted that Belgium had “deliberately and irreversibly lowered the level of protection of the rights set out in Article 3 of the Convention which the applicant had endeavoured to uphold by lodging his application with the Court” [150]. This, subsequently, had the effect of rendering a violation of the Convention otiose.  Moreover, the Court noted that the individual right of petition is accompanied by an examination of the application in accordance with the Court’s usual procedure, which has been made extremely difficult in the present case where the applicant was held in solitary confinement with “very little contact with the outside world” [153].

Read the press ECtHR press release and the original judgment


Back to top

Case referred to the Grand Chamber of the European Court of Human Rights


On the 8th September 2014 the Grand Chamber panel of five judges decided to refer the case of W.H. v. Sweden (no. 49341/10), concerning the deportation of an asylum seeker whose application has been rejected from Sweden to Iraq. In its Chamber judgment of 27 March 2014 the Court held, unanimously, that deportation of a divorced female member of the Mandaean community to Iraq would not involve a violation of Article 3, provided that W.H. was not returned to parts of the country situated outside the Kurdistan Region. The Grand Chamber will be holding a hearing in this case on 18 March 2015.

Read the W.H. v. Sweden summary

Back to top

European Union


Court of Justice: 
AG Opinion in Case C-562/13 Abdida, 4th September 2014 


(Common European Asylum System - Directive 2003/9/CE- Directive 2004/83/EC - Article 2 e)- real risk of suffering serious harm- Directive 2005/85/CE- Article 13 para 2- temporary suspension- Article 14 para 1- Guaranties pending return- Charter of fundamental rights of the European Union- Lack of remedy with suspensive effect for a decision refusing leave to remain for medical reasons-Absence of basic needs other than urgent medical needs)


Facts of the case

Mr. Abdida, a Nigerian national diagnosed with AIDS, submitted an application to the Belgian state requesting leave to remain due to medical reasons.  Under Belgian law transposing the Qualification Directive the state refused his leave to remain and an order to leave the country was issued.  When appealing against this decision, Mr. Abdida was not granted with a remedy having suspensive effect. In addition, during the litigation procedure, Mr. Abdida had his basic social security and medical care withdrawn. Domestic litigation concerning Mr Abdida’s entitlement under EU law to such suspensive remedies and social rights reached the Brussels Employment Court, which referred two questions to the CJEU.

Questions referred for a preliminary ruling

1.     On a proper construction of Directives 2004/83/EC, 2005/85/EC and 2003/9/EC,  is a Member State which provides that a foreign national has the right to subsidiary protection for the purposes of Article 15(b) of Directive 2004/83/EC if that person ‘suffers from an illness which is of such a kind as to entail a real risk to his life or physical integrity or a real risk of inhuman or degrading treatment where there is no adequate treatment for that illness in his country of origin’ under an obligation to

–    provide for a remedy with suspensive effect in respect of the administrative decision refusing leave to remain and/or subsidiary protection, and ordering the person to leave the territory of that State,
–    make provision under its social security or reception system for the basic needs of the person applying for subsidiary protection (other than his medical needs) to be met pending a ruling on his appeal against that administrative decision?

2.    If the answer to Question 1 is in the negative, does the Charter of Fundamental Rights – and, in particular, Articles 1 to 3 (human dignity, right to life and integrity), Article 4 (prohibition of inhuman or degrading treatment), Article 19(2) (right not to be removed to a State where there is a serious risk of inhuman or degrading treatment), Articles 20 and 21 (equality and non-discrimination as compared with other categories of applicants for subsidiary protection) and/or Article 47 (right to an effective remedy) of that Charter – place a Member State in course of transposing Directives 2004/83/EC, 2005/85/EC and 2003/9/EC into national law under an obligation to make provision for a remedy with suspensive effect and for the requisite means of meeting the basic needs referred to in Question 1?


Consideration of questions referred

Advocate General (AG) Bot firstly submits that the procedural guaranties and social benefits, codified in Directives 2004/83/EC, 2005/85/EC and 2003/9/EC do not apply to persons who have based their application for leave to remain upon medical reasons. Secondly, Article 13 of the 2008/115/CE Returns Directive should, according to the AG, be interpreted as opposing any national procedural rule which denies a remedy with suspensive effect. This concerns instances where a decision has been made refusing leave to remain and where the return of the individual to his country of origin, having regard to his health, may give rise to a risk of inhumane or degrading treatment, as per Article 4 of the Charter of Fundamental Rights. 

Furthermore, the AG states that Article 14 of the Returns Directive, should be read as opposing any national procedural rule which limits medical care to urgent medical care where an applicant has appealed a decision ordering his departure.  The Member State, in this type of situation, is obliged to furnish, throughout the whole litigation procedure, the basic needs of an individual as well as a dignified living standard, appropriate for his state of health, including living arrangements which take account of his individual needs.

Noting that the applicant has relied upon Article 9 of the 1980 law which relates to leave to remain for medical reasons, the AG submits that this corresponds to a form of subsidiary protection as codified in Article 2 e) of Directive 2004/83/EC [64]. He subsequently relies heavily on his own opinion in M’Bodj to confirm that a person who suffers from a serious illness, thus running a real risk of inhumane or degrading treatment due to the lack of adequate medical facilities in his country of origin, cannot be considered to benefit from subsidiary protection, Article 2 e) 2004/83/EC [66]. Given that the requirements of subsidiary protection for a person who suffers a serious illness are not met, the application of Directive 2004/83/EC, along with 2005/85/EC and 2003/9/EC are not relevant [85-91].

Underlining, however, that the Belgian authorities have regarded Mr Abdida as staying irregularly within the State since 2011, the decision to remove him is one which triggers the application of the Returns Directive  2008/115/CE [97] and as a corollary Article 51 para 1 of the Charter of Fundamental Rights [99]. Specifically, the AG highlights that Article 13 of the Returns Directive, read in conjunction with Article 47 of the Charter, implies that a remedy against the removal of an individual to a country of origin where he may face inhumane or degrading treatment, as codified in Article 4 of the Charter, must be suspensive [108].  Conversely, the AG submits that the Belgian Procedural law does not afford such an effect, given a risk of forced removal [122], risk of arrest [123], and the lack of social and economic rights which the applicant is entitled to as recognised in Article 14 2008/115/CE [124].

Moreover, the AG concludes, that whilst a reading of both Article 12 and 14 of Directive 2008/115/CE, provides a minimum level of economic and social rights for those being sent back to their country of origin [128-129], this should be interpreted in light of the Directive’s objective and the Charters' values. The AG refers, in particular, to Articles 1,2,3,4 and 35 of the Charter [154-155]. Thus, the correct reading of Article 14 2008/115/CE would be to disapply any national rule which limits an individuals need to urgent medical care where said individual has lodged an appeal against the decision by the State to expel him [158]. Instead, the Member State throughout the whole procedure is obliged to provide the individual with a level of sustenance which is dignified and corresponds to his particular needs [158].

Read the AG Opinion (French only).

Based on an unofficial ECRE translation.

Back to top

AG Opinion in Case C‑373/13 T, 11th September 2014 


(Rules on minimum standards for the qualification and status of third-country nationals or stateless persons as refugees and the content of the protection granted — Revocation of a residence permit under Article 24(1) of Directive 2004/83/EC —Concept of compelling reasons of national security or public order — Participation of a recognised refugee in the activities of a terrorist organisation)

Facts of the case

After being granted refugee status and a permanent residence status in Germany in 2006, Mr H.T, a Turkish national with Kuridsh origin, was later issued with an order for his expulsion by virtue of his alleged support in a terrorist organisation, the PKK, in 2012. Given Mr H.T’s status as a refugee with a permanent right of residence and his family ties in Germany, the enforcement of the order was suspended. Hearing the appeal of Mr. H.T, the Verwaltungsgerichtshof Baden-Württemberg referred a question to the CJEU concerning  the interpretation of Articles 21 and 24 of the Qualification Directive.

Questions referred for a preliminary ruling

(a) Must the rule contained in the first subparagraph of Article 24(1) of Directive 2004/83/EC, 1 concerning the obligation of Member States to issue a residence permit to persons who have been granted refugee status, be observed even in the case of revocation of a previously issued residence permit?
(b)    Must that rule therefore be interpreted as meaning that it precludes the revocation or termination of the residence permit (by expulsion under national law, for example) of a beneficiary of refugee status in cases where the conditions laid down in Article 21(3) in conjunction with (2) of Directive 2004/83/EC are not fulfilled or there are ‘compelling reasons of national security or public order’ within the meaning of the first subparagraph of Article 24(1) of Directive 2004/83/EC?

If the first question is to be answered in the affirmative:
(a)    How must the ground for exclusion of ‘compelling reasons of national security or public order’ in the first subparagraph of Article 24(1) of Directive 2004/83/EC be interpreted in relation to the risks represented by support for a terrorist association?
(b)    Is it possible for ‘compelling reasons of national security or public order’ within the meaning of the first subparagraph of Article 24(1) of Directive 2004/83/EC to exist in the case where a beneficiary of refugee status has supported the PKK, in particular by collecting donations and regularly participating in PKK-related events, even if the conditions for non-compliance with the principle of non-refoulement laid down in Article 33(2) of the Geneva Convention relating to the Status of Refugees and also, therefore, the conditions laid down in Article 21(2) of Directive 2004/83/EC are not fulfilled?

If Question 1(a) is to be answered in the negative:
Is the revocation or termination of the residence permit issued to a beneficiary of refugee status (by expulsion under national law, for example) permissible under European Law only in cases where the conditions laid down in Article 21(3) in conjunction with (2) of Directive 2004/83/EC (or the identically-worded provisions of Directive 2011/95/EU, the successor to Directive 2004/83/EC) are satisfied?


Consideration of questions referred

Under what circumstances can a Member State revoke a residence permit once already granted?

Faced with the question whether Member States are able to revoke a residence permit either under Article 21(2) and (3) or under Article 24(1), or whether a residence permit can be revoked only under Article 21(3) if the refugee is no longer protected against refoulement [52], Advocate General Sharpston recommends that the CJEU opt for the former [67]. Reasoning for this conclusion, according to the AG, is fivefold.  Firstly, despite submissions by Mr H.T who states that Article 24(1) does not concern revocation but the conditions applying to issuing (or refusal to issue) a residence permit, the AG conversely finds that nowhere in Article 24(1) does it explicitly exclude the use of revocation. Secondly, Article 24(1) allows for a residence permit to be withheld, thus, revocation is in consistency with the purpose of the provision. Thirdly, the AG contends that it is coherent with the scheme of the Directive for Article 24(1) to be read as allowing revocation. Fourthly, the travaux preparatoires of the Directive are congruent with the possibility to revoke a residence permit in Article 24(1) circumstances.  Finally, to come to an opposite conclusion would lead to anomalies, notably an over emphasis on the timing of information relating to an individual [68].

However, the AG also notes that “whilst it is possible to revoke a refugee’s residence permit where the Article 24(1) exception applies, it is not permissible to also withdraw or reduce the minimum level of guarantees provided for by Chapter VII of the Qualification Directive” [106]. This would not only be against the principle of proportionality but would also have the effect of leaving the individual in a “legal limbo,” depriving him of the substantive benefits that flow from his refugee status [112].  

What is meant by “compelling reasons of national security” in Article 24(1) of the Qualification Directive?

The AG initially considers whether there is an overlap between the wording of Article 21(2) and Article 24(1). Noting that the wording of Article 21(2) is more specific and thus narrower than Article 24(1) the AG considers that “compelling reasons of national security” should be interpreted as having a wider remit than the former Article. This is principally because the consequences of revoking a residence permit under Article 21(2), notably loss of protection against refoulement are far wider than the consequences of Article 24(1) [85]. Surmising that “compelling reasons…” comprise of both subjective and objective elements [86], the AG concludes that the Member States when faced with understanding this phrase should take note of the refugee’s precise actions, the actions of the organisation with which the individual has supposedly participated in, and any further circumstances which “create an enhanced likelihood of a threat to national security or public order” [102]. In the present circumstances of Mr. H.T, the AG concludes that attending lawful meetings does not constitute a terrorist activity in itself, “more would be needed to conclude that a person was a terrorist and/or that he was actively affiliated to a proscribed organisation and that the conditions of the Article 24(1) exception were accordingly met” [103].

Read the AG Opinion

Back to top

 

European Parliament:
Report on Humanitarian Visas 


A study, drawn up by the Policy Department C: Citizens' Rights and Constitutional Affairs, analyses existing EU legislation and practice on the issuing of humanitarian visas. With the aim of providing the LIBE Committee with an assessment of the possibility to issue humanitarian visas as provided for in Articles 19 and 25 of the Visa Code, the Study examines whether this possibility has been used in the past and whether Member States should be encouraged to make use of these provisions. The study underlines that although Member States have implemented a variety of humanitarian visa schemes, they are reluctant to support EU initiatives to develop common guidelines and procedures for the issuing of humanitarian visas as a way to provide safe and legal access to the territory.  The study concludes that EU Member States have an obligation to make use of the existing provisions on humanitarian visas in the Visa Code. The study recommends that the European Parliament call for more consistent provisions on humanitarian visas as well as an independent formal procedure for the lodging and processing of applications for humanitarian Schengen visas.

Back to top

UNHCR


First Global Forum on Statelessness

The first Global Forum on Statelessness took place on the 15th-17th September in The Hague, marking the countdown to the UNHCR's Campaign to End Statelessness in 10 years, which will be launched on 4 November 2014, as part of events commemorating the 60th anniversary of the 1954 Convention relating to the Status of Stateless Persons. Panellists at the Global Forum discussed a wide range of contemporary statelessness issues, ranging from best practices by States to tackling the problem and new research to better understand the dimensions of the problem.

The forum follows on from the UNHCR’s and European Network on Statelessness’(ENS), Handbook on Protection of Stateless Persons published in July 2014. The forum further dovetails with a discussion paper by ENS which analyses whether an obligation to determine statelessness can be found within the ECHR. The paper entitled Strategic Litigation: An Obligation for Statelessness Determination under the European Convention on Human Rights? examines some key articles of the ECHR in order to assess whether an obligation to determine statelessness can be construed.

Back to top

Council of Europe


PACE report on the detention of migrant children 

The Parliamentary Assembly Council of Europe's Migration Committee has published a report calling for Member States to introduce and enforce laws banning the detention of children for immigration reasons. 

The report, published by the Committee on the 9th September, is accompanied by a draft resolution and recommendation, which stresses that States engaging in the immigration detention of children contravene the principle of the best interests of the child and commit a child rights violation. The Migration Committee has also called on the Committee of Ministers to launch a study to collect qualitative and quantitative data on child immigration detention and the use of non-custodial, community-based alternatives to detention for children and families, and to promote the sharing of these practices across Europe. Along with this, the Committee has recommended the Committee of Ministers to establish guidelines for conducting child-friendly age-assessment procedures for migrant children.
The report is due to be debated by the full Assembly on 3 October.

Back to top

The European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment publishes report on visit to Denmark


In a report which follows on from recommendations given by the CPT during their previous visit to Denmark, the CPT have focused upon the treatment of persons detained by the police and of inmates in several prison establishments, as well as psychiatric institutions and secure institutions for juveniles. The report highlights that holding centres for foreign nationals need to be maintained in a decent state of repair, that the carceral environment is limited to a minimum and that regular activities are offered regularly. 
 

Back to top

NGOs


ECRE: Second Annual AIDA Report  

On 9 September, ECRE launched the Second Asylum Information Database (AIDA) Annual Report: Mind the Gap: An NGO Perspective on Challenges to Accessing Protection in the Common European Asylum System.

The research illustrates the persistent gaps between the theory of a Common European Asylum System (CEAS), where people fleeing similar situations are treated alike, and the harsh realities facing asylum seekers in 15 EU Member States of the European Union: Austria, Belgium, Bulgaria, Cyprus, Germany, France, Greece, Hungary, Ireland, Italy, Malta, the Netherlands, Poland, Sweden and the United Kingdom. The research shows that asylum seekers’ access to accommodation and support to meet their basic needs, the grounds and conditions of detention and access to quality free legal assistance to properly protect their rights remain problematic in a number of EU Member States. 

The Asylum Information Database (AIDA) is a project of the European Council on Refugees and Exiles (ECRE), in partnership with Forum Refugiés-Cosi, the Hungarian Helsinki Committee and the Irish Refugee Council. 

Back to top

ECRE: Right to Justice: Quality Legal Assistance for Unaccompanied Children


A comparative report on quality legal assistance for unaccompanied children, coordinated by ECRE, highlights that unaccompanied children face a number of obstacles in accessing legal assistance, such as a lack of information, or a lack of support. The report, which examines the legal assistance systems in place for unaccompanied children in various migration and asylum procedures in Austria, Belgium, Bulgaria, Denmark, Italy, Spain and the United Kingdom, demonstrates that even though legal assistance is provided for by law in a number of migration and asylum procedures, it is rarely available in cases where the age of the person is disputed or during an age assessment. Moreover, the crucial role of guardians informing and supporting children in accessing legal assistance was evident from the research, nevertheless, the report found that if guardians were not appointed quickly or had heavy workloads this negatively impacted children’s access to legal assistance. Despite a number of positive initiatives and individual good practices, the report shows that even when assistance is provided, quality is affected in a number of countries by systemic factors, such as limited funding or the absence of interpretation. As part of the project, Guiding Principles on Quality Legal Assistance for Unaccompanied Children were also developed, together with indicators to monitor the implementation of the principles. 
 

Back to top

The purpose of the ELENA legal updates is to inform asylum lawyers and legal organizations supporting asylum seekers and refugees of recent developments in the field of asylum law. Please note that the information provided is taken from publicly available information on the internet. Every reasonable effort is made to make the content accurate and up to date at the time each item is published but no responsibility for its accuracy and correctness, or for any consequences of relying on it, is assumed by ECRE/ELENA. The contents of this publication can in no way be taken to reflect the views of the European Commission, UNHCR, or ECRE/ELENA and in no way purport to provide an exhaustive update on asylum law developments across Europe. For more up to date information, additions, corrections and comments please contact Amanda Taylor (ataylor@ecre.org) or Julia Zelvenska (jzelvenskaya@ecre.org).
 
       

Supported by the Fundamental Rights and Citizenship Funding Programme of the European Union and UNHCR