In an August 2023 press release, a group of experts of the U.N. Human Rights Council stated that: “We urge Greece to take steps to ensure a transparent and impartial investigation into allegations of violations of the principles of non-refoulement and non-discrimination and of the right to life involving Greek law enforcement personnel, including the Hellenic Coast Guard, and border violence.” 125 In July 2023, the FRONTEX FRO issued a fourth opinion concluding that “collective expulsions at sea and land borders in Greece, accompanied by additional associated fundamental rights violations, are conducted systematically rather than constituting isolated incidents”.126 In this context, the FRO reiterated its recommendation to the FRONTEX Executive Director to trigger the mechanism to suspend or terminate FRONTEX activities in Greece, in whole or in part, unless major changes are made. 127 In 2024, the practice of refoulements continued to be used as a “front-line” tool of Greece’s migration policy, which has been described as a “de facto general policy” of “pushbacks at land and sea border” by the UN Special Rapporteur on the Rights of Migrants, as previously noted in a 2022 report, 128 to halt the flow of refugees and to deter others from attempting to irregularly cross the borders into the country. The practice is a permanent eventuality for people crossing the borders according to testimonies, media coverage and reports. Serious incidents of alleged refoulements have been reported in which arbitrary removal of people residing on the mainland or on the islands were carried out, even of a number of asylum applicants that have been already registered in the country. In September 2024, GCR submitted its written contribution to the UN Human Rights Committee, 129 in which it provided the main points and reports concerning pushback practices, practices at the borders and ineffective investigations in pushback complaints. In November 2024, GCR submitted a third-party intervention to the ECtHR in the case of Muhammad v. Greece,130 in which it pointed to the credible, consistent and numerous allegations of pushback practices at the Greek-Turkish land and sea borders and that all related domestic criminal cases “shelved”/closed at the pre-trial stage. In June 2025, GCR submitted its written contribution to the Report on externalization of migration and the impact on the human rights of migrants of the UN Special Rapporteur for the 80th session of the General Assembly,131 providing information on push backs as an informal practise of externalization in Greece. Among others, GCR highlighted the Commissioner for Human Rights Memorandum on migration and border control, adopted following his visit to Greece in February 2025, noting that the Greek General Prosecutor’s categorical denial of systematic practices of summary returns from Greece, contradicts the judgments of the ECtHR.132 By early April 2025, it was also reported that the Fundamental Rights Office of the European Border and Coast Guard Agency (Frontex) was investigating twelve (12) cases of alleged human rights violations at the borders by the Greek Authorities, amongst which two (2) cases regarded 125 126 127 128 129 130 131 132 UN Human Rights Council, Press release: Greece: UN experts call for safe, impartial border policies and practices, 23 August 2023, available at: https://bit.ly/4aIAtTW. FRONTEX, Fundamental Rights Officer, ANNUAL REPORT 2023, July 2024, p. 12, available here. Pursuant to Article 46 (4) of Regulation (EU) 2019/1896 read as follows: “The executive director shall, after consulting the fundamental rights officer and informing the Member State concerned, withdraw the financing for any activity by the Agency, or suspend or terminate any activity by the Agency, in whole or in part, if he or she considers that there are violations of fundamental rights or international protection obligations related to the activity concerned that are of a serious nature or are likely to persist”. Report of the Special Rapporteur on the human rights of migrants, Felipe González Morales, Human rights violations at international borders: trends, prevention and accountability, 26 April 2022, para.32, available at: https://bit.ly/3VNoYpV. GCR, Submission to the UN Human Rights Committee, Greece’s State Party Report, 142nd Session, 14 October – 7 November 2024, September 2024, available here. GCR, Third Party Intervention before the European Court of Human Rights in the case Muhammad v. Greece, Application no. 34331/22, available here. GCR, GCR’s Submission to the UN Special Rapporteur’s on the human rights of migrants Report on the externalization of migration and the impact on the human rights of migrants, 10/06/2025 available here Council of Europe Commissioner for Human Rights, Memorandum on migration and border control, following the Commissioner’s visit to Greece from 3 to 7 February 2025, https://tinyurl.com/5ekra3j2 47