judgment of 7 January 2025,131 in which the Court considered the relevant Greek criminal procedures as ineffective in cases concerning pushback allegations, as none of these cases progressed beyond the preliminary investigation stage and, consequently, no proceedings were brought against those who might have been responsible. The Court therefore held that “in the present state of national practice, a criminal complaint does not constitute a remedy to be exhausted in respect of violations of Articles 2, 3 or 5 of the Convention allegedly committed in the course of refoulement”. 132 Additionally, from March 2022 to June 2025 , GCR supported 1,189 individuals at risk of pushback and/or victims of multiple pushbacks before the ECtHR by submitting 111 applications for interim measures under Rule 39, which have all been granted.133 In only 27 out of these 111 cases were the asylum seekers formally arrested by the Greek authorities and the official procedure followed. In total, 58 of those applications were filed and the ECtHR granted the R39 in 2024, testifying to the recent escalation of the pushback practices in the region of Evros. In the majority of those cases, the applicants or their relatives described to GCR that they have been victims of one or multiple pushback operations. Despite the measures granted by the Court, the majority of the victims allege that they were still subsequently pushed back to Türkiye. This highlights the frequency and periodicity of pushback cases and the clear persistence of Greece’s “de facto general policy” of pushbacks at land borders. 134 Illustratively, the 58 cases (for the year 2024) included the cases of: ❖ 12 applicants who had been granted two decisions of interim measures but, allegedly, both times were pushed back to Türkiye ❖ At least 10 cases in which Turkish applicants were pushed back and the majority of them imprisoned in Türkiye, due to their political persecution. ❖ At least 2 cases of applicants who, following their pushbacks, were deported from Türkiye to their country of origin (Syrians and Iraqis) ❖ A group of refugees who were allegedly pushed back twice from two different islets prior to their official arrest on the Greek shore. In the time period between the publication of the A.R.E. decision, on 7 January 2025 and June 2025, GCR submitted 14 requests for interim measures (R 39) to the ECtHR, all of which were granted, for 55 asylum seekers (including families with children). 20 are Turkish asylum seekers and 35 are of other nationalities (Syrian, Afghan, Iraqi, Iranian, stateless). In 2 of these cases, the applicants from Türkiye were lawfully arrested and subjected to the legal procedure by the Greek authorities; in 2 other cases, concerning 2 Turkish asylum seekers, the applicants complained that they were subjected to pushback by the Greek authorities and that after re-entering Greece they were lawfully arrested; in another 7 cases, concerning 41 asylum seekers (including children), GCR was informed that all of them were pushed back to Türkiye; 131 132 133 134 ECtHR, A.R.E. v. Greece (Application no. 15783/21), paras 200 and 228, 7 January 2025, available in French here, paras and 199. Unofficial translation to English:“198. Further to the foregoing and with regard to the criminal proceedings referred to by the Government, the Court notes that it is very clear from the case-file, and in particular from the information provided by the Government itself, that all the cases in which the competent public prosecutors had opened criminal investigations were discontinued […]. As a result, none of these cases progressed beyond the preliminary investigation stage and, consequently, no proceedings were brought against those who might have been responsible. In the light of the very large number of complaints lodged and the reports of the competent national and international institutions, which point to recurrent shortcomings that hamper the effectiveness and diligence of the criminal investigations into the alleged refoulements […] the Court considers that this situation is such as to cast serious doubt on the effectiveness of the criminal proceedings […] It therefore considers that, in the present state of national practice, a criminal complaint does not constitute a remedy to be exhausted in respect of violations of Articles 2, 3 or 5 of the Convention allegedly committed in the course of refoulement. 199. Moreover, the Court notes that the criminal complaint lodged by the applicant in the present case was dismissed by the Public Prosecutor of the Thrace Court of Appeal by order no. 41/2020, in which he held, inter alia, that "the Greek police never carry out such acts of refoulement to Türkiye" (see paragraph 48 above). Above all, the Court notes that the criminal complaint was closed after a preliminary investigation which was manifestly inadequate. Indeed, it is clear from the file that the authorities took no steps to allow the applicant's brother to testify, despite requests to do so, or to verify the authenticity of the audiovisual material submitted to them. Nor did they take the time to carry out a serious examination of the other documents in the file, such as the documents from the Turkish judicial authorities or the statements of the witnesses named by the applicant, […] The Court concludes that the applicant's case is only one of many examples of the ineffectiveness of the criminal proceedings in relation to the allegations of refoulement””. Ibid., para 198. GCR, GCR’s Information Note on interventions and on interim measures granted by the ECtHR in cases regarding pushbacks Updated on the 1st July 2025 , available here. Ibid. See also, 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. 46