10 CONCLUSION AND RECOMMENDATIONS Detaining people seeking asylum in inhumane conditions that violate their human rights and dignity is completely unacceptable, especially when less harsh and more proportionate alternatives to detention are enshrined in national law and supported by international and EU law. In addition, a number of recent legislative amendments and arbitrary administrative practices undertaken by the Greek authorities are in direct breach of EU law. The recent amendment of L.3907/11 by Article 51 L.4686/2020 provides for the possibility of detention without the obligation to first examine alternatives. This is contradictory to the Return Directive, which indicates that detention may only be possible ’unless other sufficient but less coercive measures can be applied effectively in a specific case’. 87 The lack of an individual assessment and the imposition of detention on the grounds of risk of absconding that are based on a non-exhaustive list of criteria is also not in line with the relevant provision of the EU law which provides that those criteria ’must be defined by law’. 88 In addition, detention on the grounds of public order for asylum seekers and recognized refugees is out of the scope of EU law as the Return Directive does not provide for detention for public order reasons. 89 Finally, the lack of effective legal aid is in clear breach of Article 9(6) of Directive 2013/33/EU, which lays down standards for the reception of applicants for international protection. This research has highlighted the impact of detention on asylum seekers in Greece. Oxfam and the Greek Council for Refugees call on the Greek government to implement the following changes to legislation to protect the human rights of those seeking asylum: ESTABLISH A PROPORTIONATE LIMIT TO THE DURATION OF DETENTION Current legislation allows consecutive decisions that may prolong detention for up to 18 months, or even 36 months. This is an extreme provision. Given that the Greek Constitution provides for detention of up to 18 months only in exceptional cases of very serious crimes, it is totally disproportionate to set the same time limit for administrative detention for asylum seekers. A shorter time frame would still be sufficient to allow the authorities to implement any decision to return. If return is not possible, the person in detention should be released. 24