incidents reported during 2025, nine (9) regarded incidents reported in 2024, and the last (1) regarded 2023.133 Pushbacks at land borders In relation to pushbacks at land borders, 134 the UN Special Rapporteur on the human rights of migrants already noted in 2021 that, in addition to ‘increased militarisation of the Evros land border … which has effectively resulted in preventing entry and in the summary and collective expulsion of tens of thousands of migrants and asylum seekers’, there have been allegations that ‘pushbacks are also reportedly carried out from urban areas, including reception and detention centres’.135 In a report issued in April 2022, the Special Rapporteur on the human rights of migrants stated that ‘[i]n Greece, pushbacks at land and sea borders have become de facto general policy’.136 According to the abovementioned ECtHR’s findings in its January 2025 A.R.E. v. Greece judgement as well as numerous credible reports, this “systematic practice” continued in 2024. On 21 February 2022, UNHCR expressed its concerns regarding recurrent and consistent reports from Greece’s land and sea borders with Türkiye. At least three people had already been reported to have died since September 2021 in the Aegean Sea, including one in January 2022, while almost 540 reported incidents of informal returns by Greece had been recorded since the beginning of 2020. 137 The International Organisation for Migration (IOM) has also been alarmed by increasing migrant deaths and continuous reports of pushbacks at the border between Greece and Türkiye. 138 Regarding pushbacks at the Evros land border, a June 2022 journalistic investigation reported that the Greek police were using foreigners as “slaves” to forcibly return asylum seekers to Türkiye. 139 In Greece, many legal practitioners, included GCR, have resorted to litigating cases directly before the ECtHR or UN Committees, due to the ineffective procedure in domestic courts. As per a Border Violence Monitoring Network (BVMN) report, the policy of pushbacks seems ‘to have contaminated the judiciary’.140 The majority of investigations connected to pushbacks have been closed by public prosecutors invoking lack of evidence. Many of these cases have been referred to the ECtHR as domestic remedies were ineffective.141 This legal reality was acknowledged by the ECtHR in its abovementioned A.R.E. v. Greece 133 134 135 136 137 138 139 140 141 Reuters, EU border agency reviewing 12 cases of potential rights violations by Greece, 8 April 2025, https://tinyurl.com/mwve7a7y ECRE, Greece: MEPs Confront Commission Officials over Pushbacks, People on the Move Again Caught in the Stand-off with Turkiye in the Evros Region, 9 June 2023, available at: https://bit.ly/3qqFSgk. Special Rapporteur on the human rights of migrants, Report on means to address the human rights impact of pushbacks of migrants on land and sea, 12 May 2021, available at: https://bit.ly/3WvA94I, para. 55. United Nations, Report of the Special Rapporteur on the Human Rights of Migrants, Felipe González Morales, Human rights violations at international borders: trends, prevention and accountability, A/HRC/50/31, available at: https://bit.ly/4eHO68L, para 32. UNHCR, News Comment: UNHCR warns of increasing violence and human rights violations at European borders, 21 February 2022, available at: https://bit.ly/43jYnkL. IOM, IOM Concerned about Increasing Deaths on Greece-Türkiye Border, 18 February 2022, available at: https://bit.ly/3MlQtjS. ‘…The Greek police are using foreigners as ‘slaves’ to forcibly return asylum seekers to Türkiye, In recent years there have been numerous accounts from the victims, as well as reports by human rights organisations and the media, stating that the men driving these boats speak Arabic or Farsi, indicating they are not from Greece. A months-long joint investigation with The Guardian, Le Monde, Der Spiegel and ARD Report München has for the first time identified six of these men – who call themselves slaves– interviewed them and located the police stations where they were held. Some of the slaves, who are kept locked up between operations, were forcibly recruited themselves after crossing the border but others were lured there by smugglers working with a gangmaster who is hosted in a container located in the carpark of a Greek police station. In return for their ‘work’ they received papers allowing them to stay in Greece for 25 days’. See Der Spiegel, ‘Greek Police Coerce Refugees to Commit Illegal Pushbacks’, 30 June 2022, available at: https://bit.ly/3IvTGfB and Lighthouse reports, We were slaves, 28 June 2022, available at: https://bit.ly/3MTla1G. BVMN, BlackBook of Pushbacks, December 2022, available at: https://bit.ly/3ou1EPJ, 14. Ibid. 48