Dublin

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General

According to the Ministry of Interior,[1] in 2023,  Croatia received the following incoming Dublin requests according to the categories: 30,716 request for re-acceptance (take back) and  2,496 requests for acceptance of responsibility (take charge). The Ministry of Interior highlighted that due to damage to the database and administrative burden, not all data has been updated and that deviations from the presented figures are possible.

The majority of incoming take charge requests came from Germany (1,050), France (575), Switzerland (249), Belgium (238), Slovenia (126), Italy (114), Austria (59) and the Netherlands (31). According to the criterion of responsibility, the majority of incoming take charge requests were based on article 13 (2,348) of Regulation 604/2013 and the rest were based on Article 11 (46), Article 12 (28), Article 17 paragraph 2 (18), article 10 (8), Article 8 (2) and Article 16(1).

The majority of incoming take back requests came from Germany (14,277), France (6,282), Slovenia (3,279), Switzerland (2,413), Belgium (1,322), Austria (1,237), Italy (919), Netherlands (525) and Denmark (112). According to the criterion of responsibility, the majority of incoming take back requests were based on Article 18 paragraph 1b (30,506).

As for outgoing requests, in 2023, Croatia submitted 173 outgoing requests under the Dublin Regulation in the following categories: 1141 requests for reacceptance (take back) and 32 requests for the acceptance of responsibility (take charge). Most of the outgoing requests were sent to Bulgaria (48) Greece (31), Germany (26), France (18) and Poland (17). According to the criterion of responsibility, the outgoing take charge requests were based on Article 11 (9), Article 12 (9), Article 17 paragraph 2 (6), Article 13(5), Article 8 (2) and Article 10 (1), while outgoing take back requests were based on Article 18 paragraph 1b (140) and Article 18 paragraph 1d (1) .

The total number of accepted outgoing take charge requests was 3 (Germany 2 and Austria 1) and the total number of accepted outgoing take back requests was 54 (majority by Bulgaria- 36)

In 2023, there was an increase in both incoming and outgoing transfers compared to 2022. Croatia received a total of 897 incoming transfers mainly from Germany (278), Austria (193), Switzerland (159), France (117) and Belgium (87). 12 outgoing Dublin transfers were carried out to Bulgaria (4), Germany (3), Switzerland (2), Holland (1), Poland (1) and Slovenia (1).

During 2023, Belgium requested individual guarantees from Croatia for all approved incoming requests, while Slovenia and Denmark requested individual guarantees for some approved incoming requests. During 2023, Croatia requested individual guarantees from Bulgaria and Greece for outgoing requests.[2]

Dublin statistics: 1 January – 31 December 2023

Source: Ministry of Interior, available at: https://bit.ly/3Xr1uYp.

Application of the Dublin criteria

Croatia does not use any national legislation to incorporate the Dublin III Regulation, as it is directly applicable, but refers to it in Articles 2 and 43 LITP, specifying that the application will be dismissed if the responsibility of another Member State has been established. In that respect, the LITP does not establish criteria to determine the State responsible, but the Ministry of Interior, when deciding on a case, simply refers to the criteria listed in the Dublin Regulation. The Dublin procedure is applied whenever the criteria listed in the Dublin Regulation are met.

In 2023, the most common criterion for incoming requests was Art. 18, para. 1, item b) of the Dublin Regulation, while the requests were usually accepted by the Republic of Croatia in accordance with Article 20, paragraph 5, which means that the person was previously registered as an applicant for international protection, however after expressing his intention, has left the territory of Croatia on his own while the Dublin procedure was not yet carried out. Outgoing requests were usually sent to other member states based on EURODAC HIT under Art. 18, para. 1, item b).[3]

In June 2020, a meeting was held between representatives of the Ministry of Interior and representatives of the Ministry of Labour, Pension System, Family and Social Policy to improve cooperation in the implementation of family reunification within the Dublin procedure.[4]  Following that, a standard operative procedure (SOP) has been drafted to contribute to the coordination in process of family reunification of unaccompanied minors.[5] There is no information available as to whether it has been implemented in practice in the period from 2021 to 2023.

Procedure

Within the Department for international protection procedure, officials working within the Unit for Dublin Procedure conduct Eurodac and Dublin procedures.

Where fingerprinting is temporarily impossible due to medical or other reasons, fingerprints of an applicant shall be taken as soon as those impediments cease to exist.[6]

The applicant who refuses to be fingerprinted without justified cause shall have his or her fingerprints taken by police officers without his or her consent.[7] This can also be a reason for the Ministry of Interior to issue a decision in an accelerated procedure (see section on Accelerated Procedure).[8]

According to information provided by the Ministry of Interior in 2019 applicants are informed about Dublin and Eurodac when they express the intention to apply for international protection and during the interview for the purpose of lodging the application for international protection.[9] Information is available in Arabic, English, Farsi, French, Croatian, Somali, Turkish, and Urdu.[10] The Ministry of Interior does not provide a written translation of the Dublin decision, but the decision is explained orally by the interpreter during its delivery in a language that the applicant for international protection understands.

According to the Ministry of Interior, there have been changes in the practice in relation to the CJEU ruling in Case C-670/16 Mengesteab.[11] Authorities apply the Dublin procedure before the application for international protection is lodged, i.e., from the registration of the intention to apply for international protection,[12] and the three-month deadline for issuing a “take charge” request starts running from the moment they receive the notification of registration of intention to apply for international protection by the police station (see Registration), not from the moment the application is lodged. The deadline for a “take back” request is two months from the Eurodac “hit”.

Transfers

According to the information provided by the Ministry of Interior, the time between submitting outgoing request and effective transfer to responsible member state in practice will depend on the circumstances of each case, but as a rule is no longer than 6 months. Requests which are sent based on a Eurodac hit must be sent within 2 months. In the case of “take charge” requests, the deadline for response is 2 months, and if it is a take-back request, the deadline for response is 2 weeks. The transfer is organized within 6 months from the day of the positive response, i.e., acceptance of the request, or final decision on appeal or review in case of suspension effect.

In the decision on acceptance of responsibility for an individual person, each member State states the conditions of transfer according to which accepted persons should be transferred. Transfers are announced using standardized forms, within the prescribed announcement deadlines. The most frequently used method of transfer from Croatia, as well as to Croatia, is by plane accompanied by police officers. Transfers in Croatia are carried out by land, as a rule, with Slovenia, and in some cases also with Austria, in cases of transfer of families if airline tickets for the same plane are not available.

If it is determined that Croatia is responsible, the member state that sent the request is obliged to organize the transfer. A transfer is announced for each person and the transfer date is confirmed. The border crossing where the person will arrive and the Service for the Reception and Accommodation of Applicants for International Protection are informed, for prior organization of adequate reception and accommodation. During 2023, the largest number of persons were transferred from Germany, Austria, Switzerland, France and Belgium.

All transfers of adults, including voluntary transfers, are accompanied by police officers, as Croatia Airlines requires an escort in all transfer cases to avoid possible inconvenience on the plane. According to experience so far, people agree to transfer to almost all member states, except to Greece and Bulgaria.

Unaccompanied minors travel accompanied by special guardians, and since these are voluntary transfers, the accompaniment of police officers is not required.

The costs necessary for the transfer are covered by the member state carrying out the transfer.

The Ministry of Interior reported that in 2023, no problems occurred with persons awaiting transfers to other member states and the restriction of freedom of movement was not used with the purpose of implementing Dublin transfers.

The Ministry of Interior also reported that with the entry into the Schengen area during 2023, the number of accepting responsibility for examining requests for international protection increased.

During 2023, the major challenge was the increased number of incoming requests, which resulted in an increase of transfers to Croatia. This caused a significant increase in the administrative burden on officials. Some member states organized charter flights to Croatia for the reasons of procedural economy and simplicity, which required additional commitment and efforts from the Service for International Protection, the Border Directorate and the Service for the Reception and Accommodation of Applicants for  international protection.[13]

The transfer to the responsible Member State is organised by the Unit for Dublin procedure of the Ministry of Interior, in cooperation with the receiving Member State.

Some examples of relevant case law from different EU countries on appeals against decisions allowing Dublin transfers to Croatia can be mentioned.

Denmark: The Denmark Refugee Appeals Board confirmed two Dublin transfers to Croatia on the condition of guarantees of being provided access to the asylum procedure.[14] The Refugee Appeals Board upheld the Danish Immigration Service’s decision to transfer an applicant to Croatia on the condition of the Immigration Service obtaining a guarantee from the Croatian authorities that the applicants’ asylum case would be admissible in Croatia. With regard to the reception conditions for asylum applicants, the board considered that there were no grounds to believe that there were general systemic flaws which would result in a risk of inhuman or degrading treatment as defined in Article 4 of the EU Charter.[15]

Germany: The German Higher Administrative Court of Lower Saxony decided that, despite information on pushbacks in Croatia, there are no systemic deficiencies in the asylum system regarding Dublin returnees.[16] BAMF lodged an onward appeal against a decision of the Regional Administrative Court of Hanover to cancel the Dublin transfer of several family members of Afghan nationals to Croatia on grounds that the asylum system in Croatia had systemic weaknesses due to violent pushbacks and illegal chain deportations. The Higher Administrative Court of Lower Saxony overturned the decision and held that, even though country information on the situation in Croatia showed that there were allegations of repeated pushbacks from Croatia to Serbia or Bosnia-Herzegovina, there was insufficient evidence that these violations occurred for Dublin returnees.[17]

On – 8 May 2023, the Administrative Court of Braunschweig delivered its decision 2 A 269/22.[18] The case concerned an Iraqi couple with six children who applied for asylum in Germany. Their asylum claims were rejected because they already submitted an asylum application in Croatia. Germany submitted take-back requests which were accepted by the Croatian authorities hence Germany issued deportation orders supplemented by entry-bans.

The Court first declared that arbitrary returns have been an integral part of Croatia’s interior migration management. It noted the systemic deficiencies in Croatia’s asylum system as the authorities regularly push asylum applicants back across the European Union (EU) external border without individually examining their asylum applications or deport them to Serbia and Bosnia and Herzegovina as part of chain deportations or collective expulsions. Due to available evidence, the mutual trust principle has been permanently shaken by the proven systemic deficiencies in Croatia’s asylum system and reception conditions. The Court emphasized that artificially separating risks to be faced by the Dublin returnees from those faced by the other asylum applicants is only justified if returnees are not threatened by them. However, trust in guarantees provided by Croatia is no longer justified, and a lack of independent knowledge by German authorities cannot be relied upon as it is the responsibility of the Member States to conduct investigations. The Court therefore ruled that there is a considerable risk that the applicants will be denied access to the asylum procedure if returned to Croatia while highlighting that there are insufficient indications that the cases of children might receive more consideration. Hence, the Court ruled that the deportation orders and entry-bans are unlawful.[19]

Netherlands: In the Netherland, the District Court of the Hague seated in Amsterdam annulled a decision on a Dublin transfer to Croatia, considering that the State Secretary had not sufficiently investigated the situation for Dublin transferees, in light of reports of pushbacks and ill treatment in the Member State.[20] Court ruled that the State Secretary had insufficiently investigated the risk of violation of Article 3 of the ECHR and had not reasoned adequately that the principle of mutual trust can be relied upon.[21]

In another case, the District Court of the Hague seated in Roermond ordered an interim measure not to implement a Dublin transfer to Croatia and stayed the proceedings, awaiting the judgment of the CJEU in a case concerning questions relevant to the current case.[22] The Court stated that general country information and ECtHR case law showed that Croatia had carried out pushbacks on a large scale over a long period of time. The court noted that the information provided by the Croatian authorities was insufficient to determine whether the principle of mutual trust could be relied upon. The court also stated that questions on the legality of transfers to Poland referred for a preliminary ruling in the case NL22.6989 (15 June 2022) were relevant to this case. The court therefore decided to stay the proceedings until the questions are answered by the CJEU, and to suspend the contested transfer decision until the appeal has been decided.[23]

In another case, the Council of State ruled that the interstate principle of mutual trust can be applied to a Dublin transfer to Croatia.[24] An Iranian national contested a decision on a Dublin transfer to Croatia, and the Court of the Hague ruled that the State Secretary wrongly relied on the principle of interstate mutual trust and mentioned the assessment made by the Council of State in the ruling of 13 April 2022. Upon an onward appeal by the State Secretary, the Council of State clarified that the interpretation of the previous ruling was important for the assessment of information submitted by the Croatian authorities and that, in its ruling from 13 April 2022, the Council of State referred the case back for further investigation. The Council of State noted that the investigations conducted by the State Secretary led to the conclusion that the principle of mutual trust can be applied with regard to Croatia and the Dublin transfer would not entail a violation of the EU Charter and the ECHR.[25]

Slovenia: In Slovenia, the Supreme Court upheld the Ministry of the Interior’s appeal in the case of a Dublin transfer to Croatia,[26] concluding that there were no procedural shortcomings or systemic deficiencies in Croatia’s asylum system.[27]The Slovenian Supreme Court reversed the Administrative Court decision and ruled that, in accordance with the Dublin III Regulation, the applicant would be considered as an applicant for international protection upon transfer to Croatia.[28] Due to several concerns about the applicant’s access to the asylum procedure in Croatia, the Administrative Court upheld the applicant’s appeal against a Dublin transfer and referred the case back to the Ministry of the Interior for re-examination. The Ministry of the Interior appealed the decision to the Supreme Court, which allowed it on the grounds that Croatia’s acceptance and processing of the application for international protection in this case was not flawed, despite findings that may indicate systemic deficiencies in the asylum procedure. The court stated that despite some findings that may indicate deficiencies in the asylum procedure, however, the applicant did not adduce substantial evidence to prove systemic deficiencies and a real and personal risk of inhuman or degrading treatment.[29]

In another case, Slovenian Supreme Court dismissed the applicant’s appeal against a decision on a Dublin transfer to Croatia on the grounds that Croatia had fulfilled the requirements for readmission.[30] In an appeal against the lower court decision confirming a decision on a Dublin transfer to Croatia, the Supreme Administrative Court also confirmed the contested transfer. The Supreme Administrative Court took into account that the applicant had already been involved in the international protection procedure in Croatia as his fingerprints were in the Eurodac database. Also, the applicant was considered an asylum seeker and had been informed about the procedure in a language that he understood, and he had received an invitation for an interview. The Supreme Administrative Court concluded that it could not therefore be refuted that Croatia had fulfilled the requirements for readmission.[31]

Switzerland: The Swiss Federal Administrative Court rejected an appeal against a Dublin transfer to Croatia, considering that Dublin transferees have access to the asylum procedure in Croatia.[32] Despite reports of pushbacks and several issues related to access to the asylum procedure in Croatia, the Federal Administrative Court ruled that the situation for Dublin transferees is different.[33]

In another case, the Swiss Federal Administrative Court confirmed a Dublin transfer to Croatia,[34] considering that asylum applicants have access to reception conditions and the asylum procedure. After Croatia accepted Switzerland’s request to take charge of the applicant, the applicant appealed against this decision, invoking health issues, claiming there were systemic deficiencies in the reception system and the asylum procedure in Croatia, and that she risked facing illegal pushbacks. The Federal Administrative Court found that the applicant had not demonstrated that she suffered from health issues or that the conditions in Croatia were such that her transfer could lead to a breach of Articles 3 or 4 of the EU Charter or Article 3 of the ECHR.[35]

Similarly, the Swiss Federal Administrative Court rejected an appeal against a decision on a Dublin transfer to Croatia, finding insufficient evidence of a risk for illegal expulsion or inhuman or degrading treatment.[36]A Turkish national challenged a decision on a Dublin transfer to Croatia before the FAC, claiming that the Croatian authorities prevented him from applying for asylum, denied him food and water for several hours, and threatened to deport him to Bosnia and Herzegovina. The applicant submitted a Human Rights Watch report that detailed shortcomings in the asylum system and alleged abuse of asylum seekers by government officials. The FAC cited a previous judgment, A. v State Secretariat for Migration, in which it concluded that there was insufficient evidence to suggest that those who were transferred under the Dublin procedure would be forcibly removed from Croatia without the opportunity to apply for asylum. Moreover, the court found that there was no evidence to suggest that the applicant would be subjected to cruel or inhuman treatment. As a result, the court found no reason to annul the transfer or apply Article 17(1) of the Dublin III Regulation.[37]

Personal interview

There is no special interview conducted in the Dublin procedure, since questions relevant to that procedure are part of the interview when expressing the intention to apply for international protection before the police, and also of the first interview that is conducted by the officials of the Reception Centre for Applicants for international protection upon the lodging of the application.

If there are elements in connection with the Dublin procedure which were not mentioned in the application, for instance there is a Eurodac hit and the applicant has not mentioned that he or she was in another Member State, an additional interview can be conducted.

The same procedural rules as for the regular procedure apply during this part of the procedure, and the same guarantees as for the first interview in the regular procedure will apply (see section on Regular Procedure: Personal Interview).

Appeal

The decision on the transfer includes the grounds for the application of the Dublin Regulation and information on how to lodge a lawsuit against the decision. The lawsuit, for which applicants receive free legal assistance, must be lodged before the Administrative Court within eight days from the delivery of the decision.[38]

The courts and their judges are not specialised in asylum cases. The court examines the lawfulness of the Dublin decision. A personal hearing can be omitted on the decision of the judge: therefore in some cases the oral procedure is conducted in absentia (with only the legal representative present). In Dublin cases, it happens when the complainant disputes only the application of the law and not the facts of the case, and the parties have not made a request for a hearing to be held. However according to the knowledge of the Croatian Law Centre, in practice hearings are held in Dublin cases as well.

Complaints have suspensive effect. According to the information available to the Croatian Law Centre, in the past the courts did not always take into account the level of reception conditions,[39] the procedural guarantees and the recognition rates in the responsible Member State when reviewing the Dublin decision. In 2021, as reported by one attorney, there was a case in which the Administrative Court referred the case back to the Ministry of Interior as it failed to take into account the individual circumstances of the client in the administrative procedure, and it did not thoroughly assess the situation in Greece to which the transfer was ordered.[40]

There is no publicly available data on how many Dublin decisions on transfers to other Member States were actually challenged before the Administrative Court since Croatia became an EU Member State. Therefore, no conclusions can be drawn on whether the Administrative Court takes into account the conditions and guarantees in the responsible Member state when reviewing the Dublin decision. The Administrative Court in Zagreb reported that information on Dublin cases should not  be entered in the “eSpis” application (an application used by courts), so no information is available on Dublin Cases before the Administrative Court in Zagreb in 2021, 2022 and 2023.[41]

Legal assistance

The same rules as in the regular procedure apply for access to free legal assistance during the Dublin procedure, meaning that free legal aid includes assistance in the preparation of the lawsuit and representation before the Administrative Court,[43] if requested by the applicant.

Suspension of transfers

After accessing the EU, Croatia suspended transfers of applicants for international protection to Greece. Where there was no responsible Member State other than Greece, in previous years Croatia took responsibility for the examination of the asylum application. However, from data provided by the Ministry of Interior, it can be inferred that this changed in 2017. The Ministry of Interior reported that, according to the Commission Recommendation of 8 December 2016, the Dublin Unit began sending requests to Greece in cases where, under the conditions of the Dublin Regulation, it was found out that Greece is responsible for examining an application for international protection. According to their information until August 2018, all received answers were negative and no transfer has been carried out since 15 March 2017.[44]

In 2023, 31 outgoing requests were sent to Greece, out of which 28 were outgoing take back requests.[45]

More about the suspensions of transfers to Croatia can be found above under: Transfers.

The situation of Dublin returnees

Applicants who are returned from other Member States in principle do not face any obstacles in accessing the procedure for granting international protection in Croatia. However, those who had left Croatia before the end of procedure and therefore had their case suspended, have to re-apply for international procedure (if they wish) once they return to the country, and thereby re-enter their initial procedure, in line with Article 18(2) of the Dublin III Regulation. On the other hand, persons whose application was explicitly withdrawn or rejected before leaving Croatia are considered subsequent applicants upon return, contrary to the requirements of the Regulation.[46]

For persons whose applications would be considered as subsequent applications, the admissibility of the subsequent application must be assessed based on the facts and evidence it contains, and in connection with the facts and evidence already used in the previous procedure. The LITP states that a subsequent application by a foreigner under a transfer shall be considered in the responsible member state of the European Economic Area, but a subsequent application lodged in the Republic of Croatia shall be dismissed as inadmissible. The subsequent application must be comprehensible and contain the relevant facts and evidence which arose after the decision on their initial application has become final, or which the applicant, for justified reasons, did not present during the previous procedure relating to establishing the fulfilment of the conditions for approval of international protection. The admissibility of the subsequent application shall be assessed on the basis of the facts and evidence it contains, and in connection with the facts and evidence already used in the previous procedure. When it is established that the subsequent application is inadmissible, the Ministry of the Interior shall decide on the subsequent application no later than within 15 days from the day of receiving it. The subsequent application shall be dismissed if it is established that it is inadmissible. When it is established that the subsequent application is admissible, a decision shall be issued once again on the substance of the application, and the previous decision is revoked. The Ministry of the Interior shall then issue a decision in an accelerated procedure no later than within 2 months from the day an admissible subsequent application is lodged.[47]

According to the report prepared by the Swiss Refugee Council, Dublin returnees are transferred to Zagreb airport. No NGO is available at the airport, even though for very serious cases, a psychologist may be made available. Normally, an official from the Ministry of the Interior is assigned to collect arriving people at the airport. Applicants for international protection are placed in a Reception centre for applicants for international protection. There is no different treatment or procedure for persons with special vulnerabilities. In reception centres, Dublin returnees are in general subjected to initial health examination and screening, during which basic screening of mental health difficulties are assessed. This is conducted through MdM.  According to their information, the outcome of this assessment may be shared with the Ministry of Interior, if the patient agrees with it. This is the case especially if special needs regarding the accommodation become apparent.[48]

As for the transfers to Croatia, national courts developed different practices in the evaluation of the conditions that returnees would face in the country (see more above under: Suspension of transfers).[49]

According to  MdM- BELGIQUE, in 2023, a greater number of Dublin arrivals of applicants for international protection from other EU countries to Croatia were recorded and it was observed that the transfer of persons with serious illnesses does not include the transfer of their medical documentation, which delays the continuation of treatment and continuity of care for the most vulnerable applicants for international protection who came to Croatia from other countries based on the Dublin III Regulation.[50]

[1] Information provided by the Ministry of Interior, 8 March 2024.

[2] Information provided by the Ministry of Interior, 8 March 2024.

[3] Information provided by the Ministry of Interior, 8 March 2024.

[4] At the time of the meeting, the name of the Ministry was still the Ministry for Demography, Family, Youth and Social Policy.

[5] EMN, Bulletin number 31, August 2020, available at: https://bit.ly/3XsnB0v.

[6] Article 33(6) LITP.

[7] Article 33(7) LITP.

[8] Article 41(1)(10) LITP.

[9] Information provided by the Ministry of Interior, 28 January 2019.

[10] Information provided by the Ministry of Interior, 28 January 2019.

[11] CJEU,  Judgment of the Court (Grand Chamber) in Case C‑670/16, 26 July 2017, available at: https://bit.ly/4cl8U3y.

[12] Information provided by the Ministry of Interior, 10 August 2018.

[13] Information provided by the Ministry of Interior, 8 March 2024.

[14] Denmark, Refugee Appeals Board [Flygtningenævnet], Applicants v Immigration Service, Dub-Kroa/2023/1, March 2023.

[15] EUAA: Quarterly Overview of Asylum Case Law, June 2023, available at: https://bit.ly/4afU2TB, 15.

[16] Germany, Higher Administrative Courts (Oberverwaltungsgerichte/Verwaltungsg erichtshöfe), Federal Office for Migration and Refugees (BAMF) v Applicants, No 10 LB 18/23, 11 October 2023.

[17] EUAA: Quarterly Overview of Asylum Case Law, December 2023, available at: https://bit.ly/3z29dC2 , 14.

[18] Lower Saxony Administrative Court, Verwaltungsgericht Braunschweig Urt. v. 08.05.2023, Az.: 2 A 269/22, 8 March 2023, available at: https://bit.ly/3VvdNQV.

[19] ECRE: Germany: Court revokes Dublin decision regarding the return of an Iraqi family to Croatia due to the risk of summary return; available at: https://bit.ly/3VudtlB.

[20] Netherlands, Court of The Hague [Rechtbank Den Haag], Applicant v State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid), NL23.7025 and NL23.7026, 6 June 2023

[21] EUAA: Quarterly Overview of Asylum Case Law, September 2023, available at: https://bit.ly/3RVjWVN, 13/14.

[22] Netherlands, Court of The Hague [Rechtbank Den Haag], Applicant v State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid), NL23.12018, 2 June 2023.

[23] EUAA: Quarterly Overview of Asylum Case Law, September 2023, available at: https://bit.ly/3RVjWVN, 14.

[24] Netherlands, Council of State [Afdeling Bestuursrechtspraak van de Raad van State], State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid) v Applicant, 202303599/1/V3, 13 September 2023.

[25] EUAA: Quarterly Overview of Asylum Case Law, December 2023, available at: https://bit.ly/3z29dC2, 15.

[26] Slovenia, Supreme Court [Vrhovno sodišče], Ministry of the Interior v Applicant, VS00067263, 7 June 2023.

[27] EUAA: Quarterly Overview of Asylum Case Law, September 2023, available at: https://bit.ly/3RVjWVN, 14.

[28] Slovenia, Supreme Court [Vrhovno sodišče], Ministry of the Interior v Applicant, VS00069932, 6 September 2023.

[29] EUAA: Quarterly Overview of Asylum Case Law, December 2023, available at: https://bit.ly/3z29dC2, 13.

[30] Slovenia, Supreme Court [Vrhovno sodišče], Applicant v Ministry of the Interior, VS00070338, 21 September 2023.

[31] EUAA: Quarterly Overview of Asylum Case Law, December 2023, available at: https://bit.ly/3z29dC2,  14.

[32] Switzerland, Federal Administrative Court [Bundesverwaltungsgericht – Tribunal administratif fédéral – FAC], A. v State Secretariat for Migration (Staatssekretariat für Migration – SEM), E-1488/2020, 22 March 2023.

[33] EUAA: Quarterly Overview of Asylum Case Law, June 2023, available at: https://bit.ly/4afU2TB, 15.

[34] Switzerland, Federal Administrative Court [Bundesverwaltungsgericht – Tribunal administratif fédéral – FAC], Applicant v State Secretariat for Migration (Staatssekretariat für Migration – SEM), E-2694/2023, 7 June 2023.

[35] EUAA: Quarterly Overview of Asylum Case Law, September 2023, available at: https://bit.ly/3RVjWVN, 15.

[36] Switzerland, Federal Administrative Court [Bundesverwaltungsgericht – Tribunal administratif fédéral – FAC], Applicant v State Secretariat for Migration (Staatssekretariat für Migration – SEM), F-3303/2023, 16 June 2023.

[37] EUAA: Quarterly Overview of Asylum Case Law, September 2023, available at: https://bit.ly/3RVjWVN, 15.

[38] Article 43(3) LITP.

[39] Information provided by the attorney at law, 21 January 2020.

[40] Information provided by the attorney at law, 11 January 2022.

[41] Information provided by the Administrative Court in Zagreb, 31 January 2022.; 23 January 2023., 12 January 2024.

[42] State funded free legal aid for applicants for international protection before the Ministry of Interior ended on 31 March 2020.

[43] Article 60(2) LITP.

[44] Information provided by the Ministry of Interior, 10 August 2018.

[45] Information provided by the Ministry of Interior, 8 March 2024.

[46] ECRE, Balkan route reversed, December 2016, p. 30, available at: https://bit.ly/3mWZAyE.

[47] EUAA: Information on procedural elements and rights of applicants subject to a Dublin transfer to Croatia, available at: https://euaa.europa.eu/sites/default/files/2023-05/factsheet_dublin_transfers_hr.pdf

[48] Swiss Refugee Council, Situation of asylum seekers and beneficiaries of protection with mental health problems in Croatia, available at: https://bit.ly/3DZ09MS.

[49] ECRE, The implementation of the Dublin III Regulation in 2020, September 2021, available at: https://bit.ly/3xjuHYr.

[50] Information provided by MDM-BELGIQUE, 23 February 2024.