second instance decisions rejecting requests for suspensive effect and ordering the removal of the appellant.288 Relevant data for 2022 was not provided. Procedure before the Appeals Authority Written procedure: As a rule, the procedure before the Appeals Committee is a written one and the examination of the Appeal is based on the elements in the case file. 289 The Appeals Committees shall invite the appellant to an oral hearing when: 290 (a) The appeal is lodged against a decision which withdraws the international protection status (see Cessation and Withdrawal); (b) Issues or doubts are raised relating to the comprehensiveness of the appellant’s interview at first instance; (c) The appellant has submitted substantial new elements Under L 4375/2016, the appellant could also be invited to an oral hearing if the case presented particular complexities,291 which is no longer the case. The prohibition first foreseen in Article 105 IPA on reverting cases back to the first instance posed difficulties in cases rejected by the Asylum Service as being inadmissible on the basis of the Safe Third Country concept, as asylum seekers had only been interviewed on points relating to the “safe third country” concept and not on the merits of their claim. Appeals Committees did not adopt a consistent approach: while some ordered an oral hearing for the applicant to substantiate the application on the merits,292 others proceeded directly to an assessment of the case sur dossier. This resulted in grants of subsidiary protection to applicants on the basis that they did not meet the criteria for refugee status, even though they were never requested to provide information on their reasons for fleeing their country of origin e.g. Syria.293 In 2021, 250 appellants were invited for an oral hearing before the Appeals Committees. 294 Article 111 of the Asylum Code, whilst maintaining the prohibition on reverting cases back to the first instance, provides that in cases when the Appeals Committee considers it necessary to hold an interview, the interview shall be conducted by the Committee itself, in accordance with the provisions of Article 82. 295 Obligation of the Appellant to present in person before the Appeals Committees on the day of the examination: Despite the fact that the procedure before the Appeals Committees remains written without hearings as a rule, Articles 97(2) and 78(2) and (3) IPA as well as Articles 102(2) and 83(2)(3) of the Asylum Code impose an obligation on the appellant to personally appear before the Appeals Committee on the day of the examination of their appeals on penalty of rejection of their appeal as “manifestly unfounded”.296 This is an obligation imposed on the appellant even if he/she has not been called for an oral hearing. Where an appellant resides in a RIC or Accommodation Centre, a written certification of the Head of the RIC or the Accommodation Centre can be sent to the Committee prior of the date of the examination, by which it is certified that he/she remains there. This certification should have been issued no more than 3 days prior of the examination of the appeal, or alternatively, an appointed lawyer can appear before the Committee on behalf of the appellant. 288 Information provided by the Appeals Authority, March 2022 Article 97(1) IPA and Article 102(1) ASYLUM CODE 290 Article 97(3) IPA and Article 102(3) ASYLUM CODE 291 Article 62(1)(d) L 4375/2016. 292 21st Appeals Committee, Decision 29458/2020, 19 November 2020; 10th Appeals Committee, Decision 22083/2020, 28 April 2021; 5th Appeals Committee, Decision 202299/2021, 25 August 2021; 21 st Appeals Committee, Decision 364000/2021, 4 November 2021; 21 st Appeals Committee, Decision 398486/2021, 19 November 2021. 293 5th Appeals Committee, Decision 12366/2020, 14 September 2020; 5 th Appeals Committee, Decision 12365/2020, 2 October 2020; 21st Appeals Committee, Decision 28217/2020, 7 December 2020; 10 th Appeals Committee, Decision 25173/2020, 19 November 2021; 20th Appeals Committee, Decision 29118/2020, 19 November 2021. 294 Information provided by the Appeals Authority, 2022. 295 Article 111 ASYLUM CODE 296 Article 97(2) IPA and as Articles 102(2) ASYLUM CODE 289 66