159. Moreover, the evidence to date seems to highlight that no effective investigations have been carried out into allegations of violent forcible removals from Greece to Türkiye. On 17 October 2023, the Greek Ombudsman published the 2022 Special Report of the National Mechanism for Arbitrary Incidents (Εθνικού Μηχανισμού Περιστατικών Αυθαιρεσίας – ΕΜΗΔΙΠΑ), which concludes that only one in seven internal administrative investigations by the Hellenic Police could be deemed complete and thorough. The report shows an increase, in 2022, in the number of complaints received concerning alleged pushbacks received (16 complaints)62 and in the number of cases referred to it by the Fundamental Rights Officer of the European Border and Coast Guard Agency (Frontex) (five cases)63. The report also refers to seven cases of alleged refoulement of persons already present in major urban areas of Greece.64 Further, the CPT understands that the National Transparency Authority had received over 200 documented complaints of pushbacks by June 2022. Apparently some 88 of these complaints referred specifically to incidents involving the Hellenic Coast Guard and they had been transferred to the Naval Court Prosecutor for investigation. However, there is no information on how such cases are progressing or whether the investigations are being carried out in accordance with the criteria set out by the European Court of Human Rights and its caselaw, and the standards promoted by the CPT.65 In the past, the CPT has raised questions over the effectiveness of investigations into alleged ill-treatment by law enforcement officials.66 The CPT would like to be informed of the outcome of the completed investigations undertaken by the National Transparency Authority to date and to be informed about how many complaints in total it has received relating to pushback operations. It would also like to receive information about the number of cases being examined by the Naval Court Prosecutor and the outcome of these investigations. Likewise, it would appreciate being informed whether any alleged cases of pushbacks across the land or sea borders have resulted in law enforcement officials or other individuals being charged or prosecuted. 160. Moreover, numerous accounts of alleged pushbacks have been documented by several organisations, such as Médecins sans Frontières,67 the Greek National Commission for Human Rights (GNCHR)68 and UNHCR. In particular, UNHCR stated that during 2020-2021, it recorded 539 incidents of informal enforced return at land and sea, involving at least 17 000 people, during which potential violations of several rights were reported. Among those were the rights to life and to protection from torture, inhuman or degrading treatment as well as, inter alia the right to seek asylum.69 The CPT understands that UNCHR has continued to raise concerns over such practices. The findings of the CPT during the 2023 visit concord with those documented by UNHCR. 62. This adds to the 21 pending complaints received between 2019 and 2021, and the 15 complaints that are being examined as part of the Ombudsman’s own initiative investigation. 63. In addition to the two cases referred to the Ombudsman in 2021. 64. See Greek Ombudsman, National Mechanism for the Investigation of Arbitrary Incidents (EMIDIPA), 2022 Special Report, October 2023. The delegation also received a couple of detailed allegations of persons apprehended in Thessaloniki and transported, along with other persons, to the border area in a police van. Their possessions and mobile phones were confiscated before the journey. In the border area, they stated that they were subjected to blows with sticks from a few police officers and had to undress before being pushed back across the river to Türkiye. 65. See the extract from the CPT’s 14th General Report on Combating Impunity. 66. See, for example the report on the CPT’s 2019 visit to Greece (CPT/Inf (2020) 15), paragraphs 84 to 92. 67. See MSF, In plain sight: The Human Cost of Migration Policies and Violent Practices at Greek Sea Borders, November 2023. 68. See Greek National Commission for Human Rights, Recording mechanism of incidents of informal forced returns, Interim report, January 2023. 69. See UNHCR submission to the European Court of Human Rights in the case S.A.A. and Others v. Greece (no. 22146/21) in July 2022. 48