19 registered as adults on Kos and Leros are at risk authority to order the age assessment of being detained. In the period covered by the procedure, but rather RIS was.47 In another first edition of this report—January-November case, Equal Rights requested the release of a 2021—Equal Rights represented only one client who had a copy of his birth certificate, detained unaccompanied minor. However in arguing that this was enough to raise doubt preparing this update, Equal Rights about his minority and initiate an age represented six detained unaccompanied assessment procedure under Joint Ministerial minors, although all six of them had either Decision (JMD) 9889/2020. In that case, the original identity documents or copies of police responded that the client fell outside the documents proving their minority with them scope of JMD 9889/2020 because he had a in Greece. Moreover, 5/6 children had final rejection already. 46 originally arrived on Leros. All six were eventually released through various interventions by Equal Rights and four were recognized by the authorities as minors in the process. In the summer of 2022, Equal Rights observed a brief trend in which the police were asking GAS to register suspected minors for subsequent applications, although the individuals themselves had never requested Equal Rights has also observed that many of this and often had no idea what was the minors detained during the period covered happening. When Equal Rights confronted the by this update were prima facie minors based police about this practice, they stated that it on their physical appearance alone. In one was done so that RIS would once again have instance, Equal Rights undertook a case after competency to order an age assessment one of our attorneys entered the PRDC to meet procedure. However, in many cases the person with a different client and noticed a young boy either had no grounds for or was unprepared to who was clearly underage on her way to the submit a subsequent application and doing so meeting room. After speaking with him, the risked harming their legal cases or prolonging lawyer learned that the client was indeed 17 their detention. In one case, the police and he was eventually released and transferred requested a client’s subsequent registration to a shelter in mainland Greece. In the summer without informing us as the authorized of 2022, Equal Rights addressed this issue lawyers, although the police had our directly before the police. In that conversation, authorization on file. the police acknowledged that they also Although JMD 9889/2020 does not explicitly doubted the age of several detainees but claimed that they were not the competent Social Rights, Observations by the United Nations High Commissioner for Refugees (16 August 2019), 4, available at: https://bit.ly/3Dt1BWi. 46 Detained and Forgotten, supra note 3, at 20. 47 Art. 1(2) JMD 9889/2020 states that “if any employee of the Reception and Identification Service or the Asylum Service or any competent authority for the protection of minors […] if there are any doubts about the minority of a third oblige the police to refer rejected asylum seekers to the age assessment procedure,48 country national or stateless person, at any stage of the procedure before the competent Reception Authorities and Asylum Service, shall immediately inform the Director of the Reception and Identification Centre […] who shall, by reasoned decision, order that the person concerned be referred to an age determination procedure.” 48 See Article 1(2) JMD No. 9889/13-08-2020. ‘Still detained and forgotten’ – Update on Detention Policies, Practices, and Conditions on Kos 2022/23