the Bulgarian authorities whether it was allowed under EU law to extend detention beyond eighteen (18) months in the case of migrants who hamper their own removal process, the Court of Justice replied that “It must be pointed out that, [...] Article 15(6) of Directive 2008/115 in no case authorises the maximum period defined in that provision to be exceeded.” Detaining a person on grounds of “public order and public safety [...] that he is not in possession of valid documents, his conduct is aggressive, and he has no means of supporting himself and no accommodation or means” cannot constitute grounds for allowing detention to be extended beyond eighteen (18) months10. Since the time limit set by the EU Directive is both clear and unambiguous, leaving no space for Members States to differentiate11, the Greek authorities will be violating the Directive if they do not immediately release migrants upon the expiry of eighteen (18) months. towards all migrants and its automatic extension beyond eighteen (18) months finds therefore no basis under Greek and EU law also for this reason. 3. Next to EU and Greek law, Greece is also bound by its obligations under the European Convention of Human Rights (ECHR). In order for the detention of irregular migrants to be “lawful” under Article 5 par 1(f) the Convention, the European Court of Human Rights, which issues binding judgments for the State Parties to the Convention, has developed certain principles that must be met: detention must be implemented in good faith, the place and conditions of detention must be appropriate, the duration of the detention reasonable and the authorities must process the deportation within a timely manner. Greece has already been repeatedly convicted for failing to meet these principles and for arbitrarily locking up migrants under deplorable conditions in violation of the Convention – even in cases where the detention had only lasted a few weeks14. 2) The systematic use of detention as such, let alone an indefinite one as the police authorities seek to enforce, is also unlawful because it violates a number of international and European legal obligations. As mentioned earlier, both the EU Directive and Greek law clearly state that detention of irregular migrants for the purpose of removal is a measure of last resort, the use of which must be limited and can only be maintained as long as removal arrangements are in progress and executed with due diligence 12. To be justified, there must be a real prospect that the removal can be carried out. Asylum seekers, for instance, cannot be detained on grounds that they have entered or reside in the country illegally13. The blanket application of detention In line with the Court's standards, in a recent judgment a Greek court acquitted from all charges 15 irregular migrants who had escaped from a detention centre, on grounds that the facility did not meet international standards. This by itself rendered the duration and conditions of their detention unlawful15. procedures in Member States for granting and withdrawing refugee status, available at http://eur-lex.europa.eu/legalcontent/EN/TXT/?uri=uriserv:OJ.L_.2005.326.01.00 13.01.ENG; see also Article. 12, presidential decree 113/2013. 14 See ECtHR, S.D. v. Greece, Appl. No 53541/07, Judgment of 11 September 2009; A.A. v. Greece, Appl. no. 12186/08, Judgment of 22 July 2010; Tabesh v. Greece, Appl. no. 8256/07, Judgment of 26 November 2009; Rahimi v. Greece, Appl. No. 8687/08, Judgment of 5 April 2011. 15 See Misdemeanour Court of Igoumenitsa, Decision No 682/2012 of 2 October 2012, available at https://docs.google.com/file/d/0BzLLCPJMrNIEbnF DZUdaR3VoTHM/edit . 76 Law No. 3386/2005 as amended. 10 See Court of Justice of the European Union(Grand Chamber), Case C-357/09 PPU, Said Shamilovich Kadzoev (Huchbarov) v. Directorate for Migration at the Ministry of the Interior, Judgment of 30 November 2009, par. 68-71. 11 Ibid. paras 37, 54 and 61. 12 See Returns Directive, Article 15. 13 See also Council Directive 2005/85/EC of 1 December 2005 on minimum standards on 4