that they are an applicant of international protection, asylum seekers are arbitrarily detained in PRDCs for extended periods of time, on ambiguous and excessively applied public order grounds.[161] This is echoed by the Greek Ombudsman who has repeatedly criticised the Greek authorities for issuing detention orders without prior examination of whether the "applicant’s individual conduct represents a genuine, present and sufficiently serious threat", [162] which is necessary for detention to be in line with the case law of the Council of State and the CJEU.[163] Map of the CCAC, Section C is the PRDC. [161] Mobile Info Team. 2023. "Prison for Papers": Last resort measures as Standard Procedure. Available here. [162] The Greek Council for Refugees. 2022. Grounds for Detention. Available here. [163] J. N. v Staatssecretaris van Veiligheid en Justitie [2016] CJEU (Case C-601/15), paras 65-67. See e.g. Council of State, Decisions 427/2009, 1127/2009 and 2414/2008, which highlight that a mere reference to a criminal conviction does not suffice for the determination of a threat to national security or public order. Page 48