MIGRANTS IN DETENTION PENDING TRANSFER TO RECEPTION AND IDENTIFICATION CENTRES This practice has been most evident in the Evros region at times of increased arrivals, despite the fact that it is not provided for in national legislation. Article 39 (1) L.4636/2019 stipulates that new arrivals should be referred directly to a reception and identification centre. 42 MIGRANTS DETAINED BEFORE BEING ALLEGEDLY PUSHED BACK Pushback allegations have been consistently reported in recent years, becoming more intense and chronic since 2020. Institutions such as the European Commission, 43 the European Parliament’s Committee on Civil Liberties, Justice and Home Affairs (LIBE) 44 and the UN Special Rapporteur on the Human Rights of Migrants 45 consider those allegations to be serious. Detention in these cases includes arrest, short arbitrary detention under poor or even humiliating conditions, and informal forced return to Turkey, in clear violation of international and EU law. 46 UNACCOMPANIED MINORS IN PROTECTIVE CUSTODY Despite the positive step to disallow the detention of unaccompanied minors in ‘protective custody’, 47 in practice some unaccompanied minors are still detained. The fact that detention is imposed upon so many different groups of people indicates that the practice has become generalized against migrants. Rather than being a practice of last resort, it has become the rule. 16

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