use of alternatives to detention of migrant children, and to ensure in particular that unaccompanied children in police stations, pre-removal centres, and Reception and Identification Centres are provided with immediate access to ageappropriate shelters”.19 As of today, Greek authorities have not complied with said “immediate measures.” • Non-citizens in detention are frequently deprived of fundamental procedural guarantees. In practice, detainees are not informed about their legal status, the grounds for their detention, the length of detention and the available legal remedies. In addition, their ability to challenge their detention before domestic courts is severely restricted due to the lack of a free legal aid scheme.20 Recent ECtHR case-law corroborates that in practice, major obstacles hinder effective access to the domestic legal remedy against detention.21 Moreover, despite the amendment of Greek legislation in 2010 aiming to include the examination of the lawfulness per se within the scope of the remedy, to a large extent, national remedy against detention (Objections against detention) remains non-effective as the per se lawfulness of the detention, including detention conditions, are not effectively examined in that framework. The ECtHR has found that, in a number of cases, despite the amendment of Greek law, the lawfulness of applicants’ detention had not been examined in a manner equivalent to the standards required by Article 5(4) ECHR.22 Based on the cases supported by the GCR, it seems that Administrative Courts tend not to thoroughly examine complaints regarding detention conditions. Moreover, it seems that the Objections procedure may also be marred by a lack of legal security and predictability, which is aggravated by the fact that no appeal stage is provided in order to correct the decisions of the Administrative Courts. The GCR has supported a number of cases where the relevant Administrative Courts’ decisions were contradictory, even though the facts were substantially the same.23 Finally, the ex officio judicial review of detention orders appears highly ineffective, as the review takes place in a stereotypical and rudimentary way. Official data corroborates these concerns. Out of a total 1,192 detention orders for asylum seekers examined by the Administrative Court of Athens in 2018, there were only four cases in which the ex officio review did not approve the detention measure imposed (0.3 percent of all orders).24 19 ECSR, International Commission of Jurists (ICJ), and European Council for Refugees and Exiles (ECRE) v. Greece, Complaint No. 173/2018, Decision on admissibility and on immediate measures, 23 May 2019. This was recently observed by the CPT following its 2018 visit to Greece, “CPT/Inf (2019) 4, Report on the Visit to Greece from 10 to 19 April 2018, 19 February 2019.” 20 21 ECtHR, J.R. and Others v. Greece, application No 22696/16, 25 January 2018 and ECtHR, O.S.A. v. Greece, Application No 39065/16, Judgment of 21 March 2019; Kaak and others, Application no 34215/16, 3 October 2019. ECtHR, R.T. v. Greece, application no 5124/11, 11 February 2016; Mahammad and others v. Greece, application no 48352/12, 15 January 2015; MD v. Greece, application no 60622/11, 13 November 2014; Housein v. Greece, application no 71825/11, 24 October 2013. In the case F.H. v. Greece, application no 78456/11, 31 July 2014, the Court found a violation of Article 3 combined with Article 13, due to lack of an effective remedy in the Greek context in order to control detention conditions. Likewise the Court found that “the applicant did not have the benefit of an examination of the lawfulness of his detention to an extent sufficient to reflect the possibilities offered by the amended version” of the law, see: ECtHR, “S.Z. v. Greece, application No 66702/13,” 21 June 2018. 22 23 Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018,”; Greek Council for Refugees (GCR), “Administrative Detention in Greece: Findings from the Field, 2018.” Greek Council for Refugees (GCR), “AIDA Report on Greece, Update 2018,”; UN High Commissioner for Refugees (UNHCR), “Recommendations by the Office of the United Nations High Commissioner for 24 GDP & GCR 2019 8