Grounds for detention - Asylum Information Database | European Council on Refugees and Exiles

Country Report: Grounds for detention Last updated: 19/06/26

Author

Lena Riemer, Lea Rau and Ronith Schalast

German law distinguishes several detention/custody forms relevant to asylum and return procedures, mainly regulated in the Residence Act (AufenthG) and, for airport procedures, in the Asylum Act (AsylG).

Pre-removal detention (Abschiebungshaft), § 62 AufenthG (judicial order required; detention as last resort).
- Preparatory detention (Vorbereitungshaft), § 62(2) AufenthG: detention to prepare an expulsion/“deportation order” decision where immediate decision is not possible and removal would otherwise be substantially impeded.
- Detention to secure removal (Sicherungshaft), § 62(3) AufenthG: detention to ensure removal where statutory grounds (e.g., risk of absconding) are met.
- Detention to enforce cooperation (Mitwirkungshaft), § 62(6) AufenthG: detention aimed at enforcing cooperation duties (notably identity clarification) under the statutory conditions.
- 14 Abs 3 AsylG provides that the filing of an asylum application does not automatically lift Pre-removal detention (Abschiebungshaft) where the person is already in custody.
Rejection detention (Zurückweisungshaft), § 15 Abs. 5 AsylG: detention to secure the enforcement of a refection decision (Zurückweisungsentscheidung) where immediate enforcement is not possible; duration subject to § 62 Abs 4 AufenthG.
Readmission detention (Zurückschiebungshaft), § 57 AufenthG: detention to secure readmission to another state under readmission agreements.
Custody pending departure (Ausreisegewahrsam), § 62b AufenthG: short-term custody in facilities enabling direct departure; used where immediate removal is feasible within the statutory timeframe (max. 28 days since the 2024 reform).
Detention in the airport procedure / “airport facility confinement”, § 18a AsylG: confinement of certain asylum seekers in airport facilities during the airport procedure, which German constitutional jurisprudence has not classified as “detention” in the strict sense, despite significant restrictions on movement.
Temporary holding / apprehension before a judge is reached (vorläufige Ingewahrsamnahme), § 62(5) AufenthG: In exceptional cases, the authority competent to apply for detention may hold a person without a prior judicial order if (i) there is an urgent suspicion that the requirements for detention to secure removal are met, and (ii) a judicial decision cannot be obtained in advance; the person must then be brought without delay (unverzüglich) before a judge for a decision on detention.

In 2025, the Act on the Improvement of Removals (in force since 27 February 2024) remained the key recent overhaul of detention-related rules, including (inter alia) broader detention possibilities in the context of asylum applications, longer time horizons for feasible removals, expanded grounds and powers related to identity clarification, and the extension of “custody pending departure” to a maximum of 28 days.[1] In 2025, the federal government pursued a legislative reversal of the mandatory court-appointed legal representative in proceedings on pre-removal detention and custody pending departure (Section 62d Residence Act), which had been introduced by the 2024 Act on the Improvement of Removals. The relevant bill was adopted in December 2025 and provides that the changes linked to the asylum-law amendments enter into force on 1 February 2026.

In the context of the reform of the Common European Asylum System (CEAS), adopted at EU level in June 2024 and to be applied as of June 2026, the German Federal Government adopted a cabinet draft of the GEAS-Anpassungsgesetz (CEAS Adaptation Act) on 3 September 2025, initiating the parliamentary procedure.[2] From this Adaptation Act, which was passed by both bodies of parliament (Bundestag and Bundesrat) in early 2026, significant structural changes to the German detention framework will arise when fully adopted and implemented by June 2026.

The Asylverfahrenshaft(asylum procedure detention) will be set out in proposed §§ 69–70a of the Asylum Act in the government’s CEAS Adaptation Act (GEAS-Anpassungsgesetz) as a new form of detention. Unlike all pre-existing forms of detention under German law, which are anchored in the Residence Act and ordered in the context of pending removal, this new detention form may be ordered while an asylum procedure is still ongoing – including in the regular procedure, the accelerated procedure, the border procedure, and the return border procedure (§ 70b AsylG-E). The NIP confirms that the government has selectively transposed those grounds from the new Reception Conditions Directive (EU) 2024/1346 (Article 10 ff.) for which it sees a “practical scope of application”, applying the ultima ratio[3]
A further new detention possibility – with no equivalent under current German or EU law – is foreseen for the screening phase at the external border, introduced by the EU Screening Regulation (EU) 2024/1356. The government’s CEAS adaptation legislation provides for deprivation of liberty or restriction of freedom of movement during the screening procedure itself (proposed §§ 14a–15a AufenthG-E), including a Verbringen(transfer to a location for the purpose of external border screening, § 14a(1) AufenthG-E), Überprüfungshaft (detention during external border screening, § 14a(2) AufenthG-E), Festhalten (detention during inland screening, § 15a(1) AufenthG-E), and a further Überprüfungshaft for inland screening (§ 15a(2) AufenthG-E). Since the screening procedure does not exist under current CEAS law, this constitutes a genuinely new category of liberty restriction that goes beyond anything presently possible under German or EU law. The NIP highlights that the Federal Police will bear primary responsibility for carrying out screening at external borders – in Germany, predominantly at airports and seaports – and that decisions on facility locations, technical equipment, and staff training are urgently required. PRO ASYL raises significant concerns about this framework. It argues that detention during screening should only ever be applied as a last resort, and that clear alternatives to detention – such as reporting obligations – should be established in legislation, as required by recital 11 and the definition of detention in Article 2(12) of the Screening Regulation. PRO ASYL further argues that, in particular for inland screening, there is no justification for restricting freedom of movement, as persons subject to inland screening are seeking to undergo their asylum procedure in Germany and are therefore not at risk of absconding. The draft legislation also restricts access to advisory organisations in screening facilities under certain circumstances (proposed §§ 14a(4), 15a(5) AufenthG-E), a provision PRO ASYL criticises as incompatible with the right to an effective remedy under Article 19(4) of the Basic Law, Article 13 ECHR, and Article 47(2) of the EU Charter of Fundamental Rights.[4]

Detention in the asylum procedure

An asylum application lodged after a foreigner has been detained for the purpose of removal does not always lead to release from detention, as detention is legally possible under certain circumstances. However, it has to be noted that detention pending removal, ordered solely on the grounds of illegal border crossing, is in itself not a sufficient reason to uphold such detention in case an asylum application is lodged. In addition, the authorities have to prove that there are further reasons for the prolongation of detention, such as a risk of absconding or an illegal stay for a duration of one month. The lodging of a subsequent or second application also does not preclude the ordering of detention unless the BAMF has decided to open another asylum procedure. [5]

The second possibility for detention during the asylum procedure was introduced in 2020 and relates to persons who are subject to an entry ban and present ‘a significant danger to their own or others’ lives, or to internal security’ or have been convicted for criminal offences, including asylum seekers (Section 62c Residence Act). According to the government, the provision is meant to allow for the detention of persons who are obliged to leave the country and who file an asylum application.^[6] NGOs such as PRO ASYL and the Federal Association for Unaccompanied Minors heavily criticised the new provision as it contains no safeguards for vulnerable groups and lacks a proper legal basis in the grounds for detention as provided by the EU Reception Conditions Directive.^[7]

If the lodging of an asylum application does not lead to release from detention, a detained person may be kept in detention until the BAMF has decided upon the case, but for a maximum of four weeks after the asylum request has been submitted to the BAMF.[8] Detention may even be upheld beyond that period if another country has been requested to admit or re-admit the foreigner on the basis of European law, i.e. the Dublin Regulation, or if the application for international protection has been rejected as inadmissible or as manifestly unfounded.^[9]

Pre-removal detention (Abschiebungshaft) (including Dublin removal)

Pre-removal detention is ordered to secure removal to the country of origin or to a third country (usually in the form of a Dublin transfer). It can only be ordered for asylum seekers in the situations described above. The German Constitution provides that detention may only be ordered by a judge. The responsible authorities may only take a person into custody if there is reason to believe that this person is trying to abscond to avoid removal and if a judge cannot be requested to issue a detention order beforehand. In such cases, the detention order must be subsequently obtained from a court as soon as possible.

A judge may issue a detention order as ‘preparatory detention’ (Vorbereitungshaft) in cases of persons who have been expelled (usually following a criminal conviction) and in cases of persons who have been given a removal order on the grounds that they pose a risk to national security.^[10] In most cases, however, a detention order is issued for the purpose of ‘securing the removal’ (Sicherungshaft). This type of detention is defined in Section 62(3) of the Residence Act.

This provision underwent a major amendment in August 2019 as part of the so-called Second Act for an Improved Enforcement of the Obligation to Leave the Country (Zweites Gesetz zur besseren Durchsetzung der Ausreisepflicht, also known as the ‘Orderly Return Act’/Geordnete-Rückkehr-Gesetz). Section 62(3) of the Residence Act now states that a foreigner shall be placed in detention pending removal ‘if:^[11]

there is a risk of absconding;
the foreigner is required to leave the country on account that they entered the territory unlawfully; or
a removal order has been issued pursuant to Section 58a [against persons who have been expelled or who have been found to pose a risk to national security] but is not immediately enforceable’.

However, detention remains lawful only when removal cannot be ensured by other, less severe means.^[12] Authorities have discretion to refrain from ordering detention if the person credibly demonstrates that they do not intend to evade the removal.^[13] The detention order is unlawful in cases where it is clear that the removal cannot take place within 3 months for reason outside the control of the detained person.^[14] This period was extended to six months for persons with a criminal conviction (unless the person is subjected to juvenile criminal law) with a reform that entered into force on 31 December 2022.^[15] Further changes entered into force with the Act on the Improvement of Removals in 2024, which extended this 3-month period to 6 months in general cases, not only for those with a criminal conviction. In addition, the grounds for pre-removal detention were expanded to include cases where individuals had entered the country legally — for example, visa-free or with a Schengen visa — but subsequently overstayed the permitted duration of their legal stay.[16]

The amendments introduced in 2019 through the ‘Orderly Return Act’ (Geordnete-Rückkehr-Gesetz) also established a new ground of detention to ‘enforce cooperation’ with the authorities (Mitwirkungshaft, Section 62 (6) Residence Act). This form of detention can only be applied in the following cases:

the foreign national
a) failed, without excuse, to comply with such an initial order, or failed to provide the information necessary to establish his or her identity; or
b) failed, without excuse, to comply with an order under section 82(4), first sentence, to appear in person at an appointment at the competent authority, or failed at the appointment to provide the information necessary to establish his or her identity; and
the foreign national had previously been informed of the possibility of being taken into custody (detention for the purpose of cooperation).

The maximum period foreseen for this detention ground is 14 days and is subject to a court order, which means that the authorities may not carry out short-term arrests on the basis of this provision. There is no information or case law available as to whether this ground for detention has been implemented since it entered into force in August 2019. In January 2020 media reports seemed to suggest that the new ‘detention to enforce cooperation’ had not been used yet,^[17] but it was not entirely clear from these reports which type of detention they were referring to. Data from Germany’s largest detention facility in Büren (North Rhine Westphalia), for 2023, show that the instrument is used, but only comparatively rarely with 5 cases over the first half of 2024.[18]

Risk of absconding

With the 2019 amendments, two new sub-paragraphs 62(3a) and 62(3b) Residence Act were introduced which contain an extensive definition of the grounds which may lead to the assumption of the risk of absconding (Fluchtgefahr). According to section 62(3a) a risk of absconding is to be assumed (as a refutable assumption), if:^[19]

the foreigner is providing the authorities with misleading information about their identity or has done so in connection with the planned removal or with possible impediments to removal and has not corrected false information on their own initiative, in particular by withholding or destroying documents or by claiming a false identity;
the foreigner has been asked to remain at the disposal of the authorities at a certain place to carry out an official hearing or a medical examination and was not present at this place without good reason;
the deadline set for leaving the country has expired and the foreigner has changed their place of residence without notifying the foreigners‘ authority of an address at which they can be reached, in spite of having been informed about his/her obligation to do so;
the foreigner has been banned from (re-)entering Germany and has not been granted an exceptional permission to enter Germany in spite of such a ban;
the foreigner has avoided removal in the past;
the foreigner has expressly declared that they will resist removal.

Section 62(3b) of the Residence Act then defines ‘specific indications’ for risk of absconding as follows:

The foreigner has provided the authorities with misleading information about their identity in a manner which might result in an impediment to removal and has not corrected this piece of information on his/her own initiative, in particular by withholding or destroying documents or by claiming a false identity;
The foreigner has paid substantial amounts of money, in particular to a third person [a smuggler or a trafficker] and it can be concluded under the individual circumstances that they will resist removal because otherwise their expenditures would have been of no avail;
The foreigner poses a significant risk to life and limb of third persons or to ‘significant legal interests of national security’;
The foreigner has been sentenced repeatedly to at least one prison term for intentional criminal offenses;
The foreigner has failed to obtain a passport or has refused or omitted to cooperate with authorities to fulfil other legal requirements for the clarification of his/her identity. The foreigner must have been informed in advance about the possibility of detention in case they did not comply with the aforementioned obligations;
The foreigner has repeatedly failed to comply with an obligation imposed by the authorities to take up residence in a particular region or place [residence obligation] or with other obligations imposed by the authorities to secure and enforce the removal order;
A foreigner who has entered the country legally but is now obliged to leave, cannot be apprehended by the authorities, because they do not have a place of residence at which they are predominantly staying.

It has been noted that the relationship between the newly introduced sub-paragraphs 62(3a) and 62(3b) Residence Act is not entirely clear.^[20] The Explanatory Memorandum to the new Act states that the ‘indications’ listed in Section 62(3b) aim to define the more concrete grounds, whereas the ‘assumptions’ listed in Section 62(3a) ‘allow for a more reliable prognosis’ as to whether a person is trying to avoid removal.^[21] This seems to imply that the ‘assumptions’ listed in sub-paragraph 3a are supposed to serve as additional grounds for detention, while the concrete evidence as listed in Section 3b would provide the basis for a possible detention order as ‘objective criteria’. However, the wording of the law does not support this interpretation: according to the law, a detention order can be based both on the ‘assumptions’ of sub-paragraph 3a and on the ‘indications’ of sub-paragraph 3b. The 2019 amendments therefore simply seem to have expanded the list of possible grounds for detention, rather than clarifying the preconditions for detention orders.

The new provisions have been criticised for their contradiction with the principle of detention as a ‘last resort’. Furthermore, it has been pointed out that the concept of a ‘refutable assumption’ as it is now set out in paragraph 3a is vaguely worded and places the full burden of proof on the individual who has to provide evidence that he/she is not trying to evade removal. Furthermore, Article 15 of the Return Directive (2008/115/EC) does not refer to the concept of a ‘refutable assumption’ as sufficient grounds for a detention order. For this reason, it is doubtful whether the amendments, in particular, the concept of the ‘refutable assumption’ of sub-paragraph 3a are in line with the Return Directive.^[22]

Detention in the context of the Dublin procedure

Section 2(14) of the Residence Act further contains special provisions for detention in the course of Dublin procedures (also referred to as Überstellungsgewahrsam / transfer detention). As a general rule, this section provides that most of the grounds for detention referred to above have to be regarded in the context of this provision as well: thus, the grounds listed in Section 62(3a) of the Residence Act shall apply accordingly to constitute a ‘refutable assumption for a risk of absconding within the meaning of Article 2 of the Dublin III Regulation.’ The grounds listed in Section 62 (3b) No. 1-5 of the Residence Act shall be regarded as objective criteria to assess a risk of absconding within the meaning of Article 2(n) of the Dublin III Regulation.

With the general reference to the ‘risk of absconding’ as defined in Section 62, the expansion of possible grounds for detention is applicable to the transfer detention in Dublin cases as well. NGOs have raised doubts as regards the compliance of this provision with the Dublin III Regulation.^[23] According to the latter, Member States may detain the person concerned only if there is a significant risk of absconding and on the basis of an individual assessment (Article 28 II of the Dublin III Regulation). In contrast, German law lists numerous grounds for detention, some of which are vaguely worded thus raising the question as to whether they constitute significant reasons to assume a risk of absconding.

In addition, Section 2(14) of the Residence Act defines two other criteria for a ‘risk of absconding’:

An asylum seeker has left another Dublin Member State before their asylum procedure (or Dublin procedure) had been concluded in this state and if there is no indication that they are going to return to the responsible Member State in the near future.
An asylum seeker has repeatedly applied for asylum in another Dublin Member State (or several other Dublin Member States) and has left this state before the asylum procedure had been concluded.^[24]

Through the introduction of another amendment in 2019, which is similar to an existing provision on detention pending removal, the authorities are now expressly given competence to temporarily detain people if there is a risk of absconding and if a court order cannot be obtained immediately. This can be regarded as providing a legal basis for what has been common practice. In these cases, authorities have to present the case to a court as soon as possible (Section 2 XIV 4th sentence of the Residence Act).

Since January 2025, a “pilot procedure” in the area of responsibility of the Federal Police Directorate Munich has reportedly linked ongoing border controls at the German-Austrian border to a Dublin procedure conducted under detention conditions. This pilot is a 2025 frontloading element of the Pact implementation. According to PRO ASYL, asylum seekers who were previously registered in another EU Member State (e.g., identified through a EURODAC hit) are, instead of being referred to reception facilities for a regular procedure, immediately placed in a removal detention facility and processed for a swift Dublin transfer to the responsible Member State.[25] PRO ASYL reports that, in this setting, detention is frequently justified with an asserted “risk of absconding,” and that the Dublin procedure is effectively accelerated by being carried out in detention, where shortened time limits apply; PRO ASYL points to Article 28 Dublin III Regulation, under which transfer detention may last up to six weeks. PRO ASYL further claims that the practice also affects vulnerable persons, and describes detention decisions in which indications such as expressed suicidal ideation were interpreted as suggesting a risk of absconding rather than triggering prioritised protection or health measures.

With regard to legal safeguards, PRO ASYL argues that the accelerated, detention-based procedure undermines effective access to remedies in practice, since detainees often cannot make meaningful use of legal counselling and judicial remedies within the shortened deadlines. As an illustration, PRO ASYL describes the case of a young Syrian woman apprehended at the border, detained in a nearby removal detention facility, and – after her application was rejected as “inadmissible” within about twenty days – transferred to Bulgaria after nearly six weeks in German detention; PRO ASYL reports that she was subsequently detained again by Bulgarian authorities.

A 2026 BGH ruling clarified that detention is inadmissible if transfer obstacles (e.g., capacity issues in Italy) are known, emphasizing proportionality.[26] In 2025, only 5,377 transfers occurred despite 23,912 approvals, with 30,778 deadlines expiring due to obstacles.[27]

Custody pending departure (Ausreisegewahrsam)

According to Section 62b of the Residence Act, ‘custody pending departure’ (Ausreisegewahrsam) can be carried out in the transit zones of airports or in other facilities ‘from where a direct departure is possible without having to cross a long distance to reach a border crossing point’.^[28] This does not mean that this type of detention is limited to facilities close to airports , it is also carried out in other detention facilities (see Place of detention).

Following the 2024 Rückführungsverbesserungsgesetz, custody pending departure may be ordered by a judge for up to 28 days (previously: 10 days) irrespective of the requirements for detention pending removal (Sicherungshaft) and in particular irrespective of whether there is a risk of absconding. It may be ordered if the time limit to leave the country has expired (subject to statutory exceptions), if it is established that removal can be carried out within that period, and if the person has shown behaviour indicating that removal could be made more difficult or impossible—e.g. breach of statutory cooperation duties, deception about identity or nationality, conviction for an intentional offence (excluding fines up to a total of 50 daily rates), or an overstay of more than 30 days.

De facto detention at the airport

Asylum seekers can be apprehended and de facto detained in a closed ‘airport facility’ during the airport procedure under Section 18a Asylum Act, which takes place in the airport’s transit context. Although they are confined within the premises of a dedicated facility for the duration of the airport procedure, according to the Federal Constitutional Court, being held at the transit zone is not considered detention in terms of the law.^[29]

In practice, the applicant receives a decision of placement in the facility. For example, persons placed in the detention centre of Munich Airport receive a ‘notification of residence in the airport facility’ (Bescheinigung für den Aufenthalt in der Flughafenunterkunft) for the purpose of the airport procedure under Section 18a of the Asylum Act. This notification expressly states that this form of residence is not a freedom-restrictive measure. The legal fiction of non-entry into the territory is maintained, even if the person is transferred to a hospital or to court. Police officers must escort the person whenever they leave the facility to preserve this legal construct.

However, this interpretation has been challenged by European jurisprudence in reference to similar practice in other countries. The European Court of Human Rights (ECtHR) has found that holding individuals in transit zones for prolonged periods, under continuous supervision and without the possibility to freely leave, constitutes deprivation of liberty.[30] Similarly, the Court of Justice of the European Union (CJEU) has held that such restrictions qualify as detention under EU law, especially when there is no legal alternative or meaningful access to exit options.[31] Given these rulings, airport transit zones – though not formally classified as detention under German law – may in effect operate as de facto detention facilities, raising concerns about the adequacy of legal safeguards and the compatibility of the practice with European human rights standards.

[1] Federal Government, Entwurf eines Gesetzes zur Bestimmung sicherer Herkunftsstaaten durch Rechtsverordnung und Abschaffung des anwaltlichen Vertreters bei Abschiebungshaft und Ausreisegewahrsam, 21/780, 7 July 2025, available in German here; AIDA, Country Report Germany – Update on the year 2024, June 2025, available here.

[2] PRO ASYL, GEAS-Umsetzung in Deutschland: Mit voller Härte, 16 September 2025, available in German here.

[3] Federal Ministry of the Interior, National Implementation Plan, 20 December 2024, available in German here.

[4] PRO ASYL, GEAS-Umsetzung in Deutschland: Mit voller Härte, 16 September 2025, available in German here.

[5] Sections 7(8), 71a(2) Asylum Act.

^[6] Deutscher Bundestag, ‘Bundestag verschiebt Zensus in das Jahr 2022, 5 November 2020, available in German at: https://bit.ly/3H2nY6U.

^[7] PRO ASYL, Stellungnahme zum Entwurf eines Gesetzes zur Einführung eines § 62c Aufenthaltsgesetz’, 16 July 2019, available in German at: https://bit.ly/3ItbtSy.

[8] Section 14(3) Asylum Act.

^[9] Section 14(3) Asylum Act.

^[10] Section 62(2) Residence Act.

^[11] Unofficial translation by the author, with minor abridgements.

^[12] Section 62(1) Residence Act.

^[13] Section 62(3) Residence Act.

^[14] Section 62(3) Residence Act

^[15] Section 62(3) Residence Act.

[16] Informationsverbund Asyl & Migration, ‘Rückführungsverbesserungsgesetz tritt in Kraft’, 26 February 2024, available here.

^[17] br.de, ‘Kein Bundesland nutzt ‘Geordnete-Rückkehr-Gesetz‘‘, 3. January 2020.

[18] Ministry for Children, Youth, Family, Equality, Refugees and Integration of North Rhine Westphalia, „Sachstandsbericht Unterbringungseinrichtung für Ausreisepflichtige (UfA) in Büren“, quarterly report available on the website of the Federal State parliament: https://bit.ly/49r2hvD.

^[19] Unofficial translation by the author, with abridgements.

^[20] Stefan Keßler, Freiheitsentzug ad libitum? Die Auswirkungen des „Hau-Ab-Gesetzes II’ auf die Abschiebungshaft, in: Das Migrationspaket, Beilage zum Asylmagazin 8-9/2019, available in German at: https://bit.ly/3boa7HM, 44-54 (45).

^[21] Explanatory memorandum to draft bill, Parliamentary document 19/10047, 10 May 2019, 39.

^[22] PRO ASYL, Stellungnahme zum Entwurf eines Zweiten Gesetzes zur besseren Durchsetzung der Ausreisepflicht (BT-Drucksache 19/10047), 29 May 2019, available in German at: https://bit.ly/2WqrSlt, 16.

^[23] Ibid., 5.

^[24] PRO ASYL, Stellungnahme zum Entwurf eines Zweiten Gesetzes zur besseren Durchsetzung der Ausreisepflicht (BT-Drucksache 19/10047), 29 May 2019, available in German at: https://bit.ly/2WqrSlt, 5.

[25] PRO ASYL, Im Schnellverfahren zurück nach Bulgarien, 13 May 2025, available in German here.

[26] BGH, Decision of 17 December 2025 – XIII ZB 8/23, available in German here.

[27] Federal Government, Reply to parliamentary question by The Left, 21/4911, 20 March 2026, available in German here.

^[28] Section 62b(2) Residence Act.

^[29] Federal Constitutional Court, Decision of 14 May 1996, 2 BvR 1516/93. See also Federal Supreme Court, Decision V ZB 170/16, 16 March 2017, available in German at: http://bit.ly/2oRx9B4.

[30] Hungarian Helsinki Committee, ‘European Court of Human Rights: Hungary’s detention of asylum seekers in transit zones condemned’, 22 November 2023, available here.

[31] PICUM, ‘Immigration detention in transit zones: What European courts say’, 18 January 2024, available here.

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