regard to the effectiveness of the remedy are equally valid (see Regular Procedure: Appeal). Thus, among others, the application for annulment before the Administrative Court does not have automatic suspensive effect, even if combined with an application for suspension. Suspensive effect is only granted by a relevant decision of the Court. This judicial procedure before the Administrative Courts is not accessible to asylum seekers without legal representation. According to practice, appellants whose appeals are rejected within the framework of the fast-track border procedure might be immediately detained upon the notification of the second instance negative decision. In the past and in particular up until March 2020, this would mean that they would be in imminent risk of readmission to Türkiye However, since readmissions remain frozen for the last three years, the detention of the people with a second negative decision serves no purpose whatsoever and is considered a disproportionate measure. In general, the Asylum Service registered subsequent asylum applications despite pending applications for annulment before the Administrative Court; both procedures can run in parallel. Concerns regarding the effective access to judicial review for appellants for whom their appeal has been rejected within the framework of the fast-track border procedure, i.e. who remain under a geographical restriction on the Aegean Islands or are detained on the Aegean Islands following the notification of the second instance decision were not abolished by the new Asylum Code, as the relevant article 115 (2) IPA remains in force.438 More specifically, Article 115(2) IPA foresees that the First Instance Administrative Court of Athens is the competent Court for submitting legal remedies against second instance negative decisions with regards to applications submitted on the Aegean islands. Thus, legal remedies regarding appellants who reside or even are detained on the Aegean Islands, should be submitted by a lawyer before the Administrative Court of Athens. By taking into consideration the geographical distance and the practical obstacles (for example to appoint a lawyer able to submit the legal remedy in Athens) this may render the submission of legal remedies non accessible for those persons.439 Furthermore, legal aid actors on the islands mention as a further impediment in the overall procedure, that most of the notaries operating on the islands deny to proceed with cases of rejected asylum seekers that wish to submit legal remedies against the second negative decision and have to appoint their legal representative via a notary. This is a serious obstacle in the submission of a legal remedy, especially in the cases of rejected applicants under geographical limitation that are restricted to leave the island of their arrival. Given the constraints that individuals geographically restricted or detained in the Aegean Islands face visà-vis access to legal assistance, the fact that legal aid is not foreseen by law at this stage, as well as that an application for annulment can only be submitted by a lawyer, and lack of prompt information about impeding removal, access to judicial review for applicants receiving a second instance negative decision within the framework of the fast-track border procedure is severely hindered. 438 439 Article 148(a) Asylum Code. Mutandis mutandis ECHR, Kaak v. Greece, Application No 34215/16, Judgement of 3 October 2019. 102