and in 3 cases, concerning 8 Afghan applicants (families with young children) and 2 Turkish applicants, GCR did not receive any information on their whereabouts.135 In 2023, GCR issued its report entitled “At Europe’s Borders: Pushbacks Continue as Impunity Persists”,136 which provides detailed descriptions of a number of cases legally represented by GCR before the ECtHR in 2023 and which underlines the organised nature of pushback practices and the systemic issue of ineffective investigations into reports and complaints relating to pushbacks and rights violations by domestic Courts, which eventually contribute to an environment of impunity. Greece ranks second in Europe in terms of the number of cases in which the ECtHR granted interim measures for the period 2022-2024,137 according to statistics published by the Court. According to these statistics, the Court has granted 222 interim measures related to Greece. Among them, and for the same period 2022-2024, the ECtHR granted interim measures in 97 cases represented by GCR in which the applicants were facing a risk of refoulement from Greece. Since 2019, GCR has filed 24 full applications before the ECtHR related to pushback cases, the majority of them connected to land pushbacks in Evros, which are still pending before the Court. A number of these cases are included, inter alia, in GCR’s report “At Europe’s Borders: Pushbacks Continue as Impunity Persists” published in November 2024.138 A number of victims that were represented by GCR, have also recorded the alleged pushback incident in the Recording Mechanism for Incidents of Informal Forced Returns of the GNCHR, abovementioned. In its annual review of Greece for of the events of 2024, Human Rights Watch stated that “violations of asylum seekers and migrants’ rights persisted in 2024, with reports of pushbacks”. 139 On 26 January 2023, the ECtHR delivered its judgment in the case of B.Y. v. Greece, application no. 60990/14,140 which was represented by GCR, the Network of Social Support of Refugees and Immigrants and the Lawyers’ Group for the rights of Refugees and Immigrants. The Court ruled that there was a violation of Article 3 (the procedural limb of Article 3 in conjunction with Article 13) of the Convention. The case concerned a Turkish national who alleged that he was forcibly removed from Athens to Türkiye, despite his attempts to claim asylum on the grounds of his political opinion. The ECtHR, by a majority of 4 votes against 3, did not uphold the plea of violation of Article 3 in its substantive part because, despite the abundance of evidence submitted, the majority of the Court maintained reservations and ultimately concluded that it was impossible to admit the applicant's presence in Greece during the period in question. The Court notes, however, that that failure stems to a large extent from the failure of the national authorities to carry out the thorough and effective investigation which they were required to carry out and to provide the necessary evidence. On the contrary, the three Members of the Court, in a strong joint minority opinion, held that Greece should be condemned also on the substantive part of the violation of Article 3 ECHR. In November 2023, via Circular 18/2023, the Deputy Prosecutor (Αντιεισαγγελέας) of the Supreme Court of Greece asked from public prosecutors to study the aforementioned decision, inter alia noting that “the prompt, thorough/detailed, impartial and real/effective criminal investigation of any such case […] greatly reduces the risk of adverse ECtHR rulings for our country”.141 After the decision of the ECtHR, the criminal investigation at a domestic level re-opened. In the recent CPT Report on its ad hoc visit to Greece, which took place from 21 November to 1 December 2023, published on 12 July 2024,142 the CPT underlines that: 135 136 137 138 139 140 141 142 GCR, News for the Field, June 2025, available here. GCR, At Europe’s Borders: Pushbacks Continue as Impunity Persists, November 2024, available here ; see also GCR, At Europe’s Borders: Between Impunity And Criminalization, March 2023, available here. Interim Measures listed by respondent State processed by ECtHR for the period 2022-2024, Dashboards updated in 31 January 2025, available here. GCR, At Europe’s Borders: Pushbacks Continue as Impunity Persists, November 2024, available here. Human Rights Watch, Greece: Events of 2024, 2025, available here. Decision available (in French) at: https://bit.ly/45nE0oF. See also ELENA, ECtHR: Greece’s ineffective investigation into an asylum seeker’s removal to Türkiye violated Article 3, 26 January 2023, available at: https://bit.ly/45rVS1O and GCR Press release available in Greek at: https://bit.ly/43pnzqh. Lawspot, Καταδίκη της Ελλάδας στο ΕΔΔΑ για ποινική έρευνα μη ταχεία, διεξοδική/εμπεριστατωμένη, αμερόληπτη και πραγματική/αποτελεσματική (Εγκύκλιος ΕισΑΠ 18/2023), 6 November 2023, available in Greek at: https://tinyurl.com/4vfhdru2. CPT, Report to the Greek Government on the visit to Greece carried out by the European Committee for the Prevention of Torture and Inhuman or Degrading Treatment or Punishment (CPT) from 21 November to 1 December 2023, published on 12 July 2024, available here. 47