officio reviews were conducted by the Administrative Courts of Corinth (4,128), Kavala (1,489) and Athens (1,281). Of those, 6,557 concerned detention of asylum seekers and 1,935 related to pre-removal detention.25 According to official statistics, administrative courts approved 41.6% of objections lodged before them in 2021 but quashed no more than 0.68% of detention orders reviewed ex officio, whilst applying the same legal standards. Even where objections have been accepted, courts often err by imposing alternatives to detention e.g. residence in a specific place / island and notification of residence address to the Police,26 and/or reporting obligations,27 even though detention grounds do not apply. The sharp disparity between the two figures, i.e. the rate of release based on approved objections and on ex officio judicial review, raises serious questions and demonstrates deficiencies in judicial scrutiny and the severe effects of non-compliance by the state with its duty to offer free legal assistance to people deprived of their liberty. In short, chances of release from detention are almost zero unless a person manages to access legal assistance and representation by their own means. This should be read against the backdrop of increasing restrictions on the work of civil society organisations offering free legal assistance to detainees, through a systematic effort on the part of the Greek government to cultivate a hostile environment for NGOs, as repeatedly denounced by Council of Europe28 and United Nations bodies.29 In conclusion, judicial review of detention remains ineffective, on account of persisting, serious gaps in compliance with procedural and substantive standards, in quality of review and in uniformity of case law. This is due to the nature of the remedy of objections against detention (written procedure, presidential procedure, without any appeal possibilities against Administrative Court rulings),30 in conjunction with 25 26 27 28 29 30 Ibid. See e.g. Administrative Court of Athens, AP831/2022, 26 May 2022; AP2150/2021, 4 November 2021; AP1430/2021, 30 July 2021; AP971/2021, 24 May 2021; Administrative Court of Piraeus, AP245/2021, 18 June 2021; AP74/2021, 25 February 2021; AP19/2021, 22 January 2021; Administrative Court of Rhodes, AP72/2022, 25 May 2022; AP515/2021, 16 December 2021; AP514/2021, 16 December 2021; AP450/2021, 3 November 2021; AP449/2021, 3 November 2021; AP195/2021, 13 May 2021; AP136/2021, 24 March 2021; AP122/2021, 4 March 2021. See e.g. Administrative Court of Athens, AP119/2022, 28 March 2022; AP2150/2021, 4 November 2021; AP2103/2021, 29 October 2021; AP1430/2021, 30 July 2021; AP971/2021, 24 May 2021; AP873/2021, 28 April 2021; AP560/2021, 11 March 2021; Administrative Court of Corinth, AP1759/2021, 2 June 2021; Administrative Court of Piraeus, AP260/2021, 5 July 2021; AP245/2021, 18 June 2021; AP74/2021, 25 February 2021. Council of Europe Commissioner for Human Rights, Letter to Greek Ministers, CommHR/DM/sf 019-2021, 3 May 2021, available at: https://bit.ly/3IqDcT8; Parliamentary Assembly of the Council of Europe (PACE), Restrictions on NGO activities in Council of Europe member States – Explanatory Report, 15205, 6 January 2021, para 33, available at: https://bit.ly/3JttcKc; Expert Council on NGO Law, Addendum to the Opinion on the compatibility with European standards of recent and planned amendments to the Greek legislation on NGO registration, CONF/EXP(2020)5, 23 November 2020, available at: https://bit.ly/3wlfHZm. UN Special Rapporteurs on the right to freedom of peaceful assembly and association για το δικαίωμα, on human rights defenders and on the human rights of migrants, Communication, OL GRC 1/2021, 31 March 2021, available at: https://bit.ly/3ud7vb6. Angeliki Papapanagiotou-Leza & Stergios Kofinis, ‘Can the Return Directive Contribute to Protection for Rejected Asylum Seekers and Irregular Migrants in Detention? The Case of Greece’, 281-299 in Madalina Moraru, Galina Cornelisse & Philippe De Bruycker (eds), Law 7 RSA LEGAL NOTE│ 2022