cannot exercise the right to be heard before the measure is imposed to him/her, and on the other hand is deprived of legal remedy for challenging the adverse administrative measure against him/her, which is subject to no maximum time limit9. In this context and due to the lack of accommodation facilities or transit facilities for minors, this “de facto detention measure” is systematically imposed for UASCs and may be prolonged for even more than eight months. In the majority of the cases, the UASCs under “protective custody” remain in border guard units till their transfer to the RIC, such as in Evros region, , in pre-removal facilities, even in police stations in the mainland, under unacceptable and degrading conditions for minors. The practice of “protective custody” has been heavily criticized as it is undoubtful that the prolonged stay of UASCs in detention facilities, “constitutes a flagrant violation of their rights and poses a direct risk to their smooth unobstructed development”10. Despite the fact that the legislation clearly provides that UASCs “shall be detained only in an extreme need, always in their best interest, ...if it is proved that alternative and less restrictive measures cannot be applied… and every effort must be made in order for UASCs to be removed from detention and be referred to accommodation facilities suitable for minors and never in penitentiaries”,11 in practice detention of UASCs is implemented as a rule and minors are subject to unfavorable conditions of deprivation of liberty. Even worse, any individualized assessment of their best interest takes place before or during detention, contrary to the Convention on the Rights of the Child, while Greece has already been convicted by the ECHR regarding the detention of children under the pretext of “protective custody” (violation of Article 3, Article 5 and Article 13). Furthermore, 2019 was yet another year stigmatized by the constant violations of human rights at the land borders of Evros, resulting to the exposure of migrants and refugees to possible ill-treatment or/and abuse. As a result, during spring of 2019, a significantly rapid increase of sea arrivals was noticed, while severe allegations of pushbacks have taken place at the land borders of Evros. In a number of cases, including cases of vulnerable persons, there are allegations of informal forcible removals (push-backs) of foreign nationals from Greece to Turkey through the Evros river. Τhe first of a series of cases of reported pushbacks in the region of Evros, which HumanRights360 is examining in collaboration with Forensic Architecture, has been published: the video corroborates several testimonies of migrants crossing the Evros/Meriç river from Turkey to Greece, who have testified to be detained, beaten, and ‘pushed back’ across the river to Turkey, by unidentified masked men and in full secrecy, without being granted access to asylum procedures. However, Greek and EU 9 "Thoughts on the protection custody of persons under Article 118 of Presidential Decree 141/1991" (Defense Legal Magazine / 1993 / pp.1041-1045) 10 Unacceptable conditions for the detention of unaccompanied minors in Northern Greece, Athens, 31 July 2017, Deputy Ombudsman for Children’s Rights of the Independent Authority, https://www.synigoros.gr/?i=childrensrights.en.news.446301 11 Article 48 of Law 4636/2019 (Article 11 of Directive 2013/33 / EU) 6|Page