This incident shows that Turkey—like Greece—is willing to engage in surreptitious and dangerous expulsions across a river border. It also shows that Turkey attempted to deport UNHCR-recognized refugees despite UNHCR’s interventions on their behalf. Furthermore, this incident shows that Turkey is still deporting Iraqis to Iraq despite UNHCR’s return advisory that it does not consider it safe for Iraqis to return to Central and South Iraq at this time. 152 Turkey’s practice, therefore, of simply deporting Iraqis who have been sent back from Greece without giving them an opportunity to have independent legal counseling or a thorough and proper individualized analysis of whether they are likely to face persecution, torture or serious harm in Iraq, constitutes refoulement. The testimonies gathered by Human Rights Watch show that the Greek authorities are systematically and summarily expelling migrants to Turkey without adequately assessing their need for protection. The risk of refoulement is foreseeable in that Greece is forcibly returning Iranians and Iraqis who may, in fact, be refugees to Turkey, and Turkey, in turn, is summarily sending these same people back to Iraq and Iran without giving them an opportunity to seek protection. Therefore, Greece’s expulsion of Iraqis to Turkey is an indirect breach of its international obligations and a violation of its own law. Principle of Nonrefoulement in Human Rights Law Under general international human rights law, states “must not expose individuals to the danger of torture or cruel, inhuman or degrading treatment or punishment upon return to another country by way of their extradition, expulsion or refoulement.”153 Greece is a party to both the 1966 International Covenant on Civil and Political Rights (ICCPR) and the 1984 Convention Against Torture and Other Cruel, Inhuman or Degrading Punishment or Treatment (CAT) carrying nonrefoulement obligations. The CAT obligation is narrower than the ICCPR in that it applies properly to where there is a risk of “torture” 152 UNHCR, “December 2007 Addendum to UNHCR’s August 2007 Eligibility Guidelines for Assessing the International Protection Needs of Iraqi Asylum-seekers,” p. 7, http://www.unhcr.org/cgibin/texis/vtx/refworld/rwmain?docid=4766a69d2&page=search (accessed August 28, 2008). Although Turkey returns the Iraqis to northern Iraq, the Kurdish authorities then send Iraqis who originate in south and central Iraq back to central Iraq. See Overland Deportations to Northern Iraq, testimony of the 28-year-0ld Sabean man (B-13). 153 General Comment No.20 (1992) of the Human Rights Committee (HRI/HEN/1/Rev.1, 28 July 1994) when commenting on Article 7 of the 1966 International Covenant on Civil and Political Rights. Stuck in a Revolving Door 66