390 Social & Legal Studies 34(3) deprivation of liberty after having entered, the Court considers that it is a relevant consideration, to be looked at in the light of all other circumstances of the case’ (para 220). As regards the second and third factors, the Court mainly emphasized the importance of procedural rights and safeguards against excessive waiting periods and the presence of a domestic legal regulation limiting the length of stay at the centre (para 227). For examining the fourth factor, the Court referred to the size of the area and the manner in which it was controlled (para 232), as well as the possibility to leave the centre (paras 234–248). Even though the Court formulated these factors as relevant for cases of both confinement to transit zones and confinement to reception centres for the identification and registration of migrants, in its case law the Court does not adopt the same approach in these two contexts. Confinement in transit zones is characterized by centres that are only open on one site. Migrants are not allowed to leave the centre to enter the territory of the host state, but they are allowed to leave the centre to return to their country of origin or to enter a third state. In these cases, the Court addresses the question whether the possibility to leave the transit zone is merely theoretical or not (Amuur v. France, 1996). The Ilias and Ahmed case was about the Röszke transit zone, situated on Hungarian territory at the border between Serbia and Hungary. In this case, the Court adopted a rather strict approach, and disregarded important legal obstacles to enter the third state, and, therefore, to actually leave the centre. It concluded that the applicants could walk into Serbian territory and the legal and practical obstacles preventing them from doing so ‘did not have the effect of making the applicants’ stay in the transit zone involuntary from the standpoint of Article 5 and, consequently, could not trigger, of itself, the applicability of that provision’.5 The conclusion was different in the case of Z.A. and others, which was about a transit zone at an airport (the Sheremetyevo Airport in Moscow). The Court distinguished this case from land border transit zones (para 154), and concluded that (para 156): having regard in particular to the lack of any domestic legal provisions fixing the maximum duration of the applicants’ stay, the largely irregular character of the applicants’ stay in the Sheremetyevo airport transit zone, the excessive duration of such stay and considerable delays in domestic examination of the applicants’ asylum claims, the characteristics of the area in which the applicants were held and the control to which they were subjected during the relevant period of time and the fact that the applicants had no practical possibility of leaving the zone, the applicants were deprived of their liberty within the meaning of Article 5. In many later cases about confinement in the Hungarian Röszke transit zone, the Court changed its position. The Court still emphasized that the applicants could have left the transit zone in the direction of Serbia at any time and that their fears about insufficient access to asylum procedures in Serbia did not have the effect of making the applicants’ stay in the transit zone involuntary from the standpoint of Article 5. However, in these cases, the Court concluded that having regard to the sum of all the other conditions, ‘in particular to the lack of any domestic legal provisions fixing the maximum duration