2 Administrative detention in Greece: Findings from the field (2018) 1. Lack of unhindered access to the asylum procedure; as a result, third-country nationals who do not manage to apply for international protection remain exposed to the risk of arrest and detention. As it was also the case during previous years, in 2018 GCR met with third-country nationals who, following repeated unsuccessful attempts to make an appointment (via Skype) with the Asylum Service, in order to apply for international protection, were eventually arrested because of the lack of legal documentation and were detained for implementing the return procedure, although they previously did not have the opportunity in practice to apply for international protection. 2. Delays in the full registration of asylum applications lodged by detainees, resulting in the deprivation of basic procedural guarantees and in delays as regards the asylum procedure in detention. GCR has observed delays in the full registration of applications for international protection for a period ranging from one to four months, during which the detainees are deprived of the procedural guarantees provided to asylum applicants. Furthermore, since the time between the expression of intention of the detainee to apply for asylum and the full registration of the application is not counted in the duration of detention of an asylum seeker, applicants for international protection may be detained for a period exceeding the maximum time limits of 3 months. Delays are also observed with regards to the conduct of the asylum procedure per se in detention. This is for example, the case of a detainee in the Corinth PRDC whose personal interview has been scheduled after the expiry of the initial 45-day detention period. Following a relevant GCR intervention, the Greek Ombudsman underlined that “where the observed delays in the asylum procedure cannot be attributed to the applicant, they do not justify the extension of detention beyond the initially determined 45-day period”. Respectively, in another case where the examination of the detainee’s appeal was scheduled on a date after the maximum detention period, the competent Court ruled that “detention is not necessary, as it does not serve any of the purposes as restrictively indicated in the law”, Judgment No 407/2018 of the First Instance Administrative Court of Kavala. Solely on a prior prosecution for a minor offence, even if no conviction has ensued, or in cases where the person has been released by the competent Criminal Court after the suspension of custodial sentences. The Ombudsman has once again criticised this practice. 3. Detention of third-country nationals on public order grounds, which are not duly justified as required by law. The invoked public order grounds are often based solely on minor offences and apply even where the competent Criminal Courts have imposed small or very small (few-day) sentences with suspension, which demonstrates that the competent Criminal Courts have already ruled that no public order grounds apply. For example, a woman, of Iranian nationality, was detained on public order grounds on the basis of a conviction imposing 40-day sentence with a three-years suspension by the Single-Member Misdemeanors Court of Athens, for the offences of illegal exit from the