reports by international organisations reaching the opposite conclusion. 859 Greek authorities come to the conclusion that applicants do not face a risk of refoulement in Türkiye on the ground that they had not already faced such treatment in the country prior to their arrival in Greece. 860 Only in a few exceptions have the Independent Appeals Committees (IACs) cited Türkiye’s practice of coercion of refugees into signing “voluntary return” forms.861 Furthermore, none of the Asylum Service and IAC decisions seen in 2024 refer to authoritative evidence on the current state and deficiencies of the Turkish asylum system, including a “20% rule” on registration of international and temporary protection claims in all provinces with a significant population of non-nationals, and removal of tens of thousands to countries such as Afghanistan and Syria. Almost none refer to the country’s “20% rule” on access to asylum procedures. 862 To GCR’s knowledge there have been certain appeals of Syrians which have been considered as admissible at second instance.863 2.2. Connection criteria Article 91(1)(f) Asylum Code requires there to be a connection between the applicant and the “safe third country”, which would make return thereto reasonable. Whereas no further guidance was laid down in previous legislation864 as to the connections considered “reasonable” between an applicant and a third country,865 the IPA, as amended by the Asylum Code, has introduced further detail in the determination of such a connection. Transit through a third country may be considered as such a connection in conjunction with specific circumstances such as: 866 (a) Length of stay; (b) Possible contact or objective and subjective possibility of contact with the authorities for the purpose of access to the labour market or granting a right to residence; (c) Stay prior to transit, e.g., long-stay visits or studies; (d) Presence of relatives, including distant relatives; (e) Existence of social, professional or cultural ties; (f) Existence of property; (g) Connection to a broader community; (h) Knowledge of the language concerned; (i) Geographical proximity to the country of origin. The article attempts to incorporate into Greek law the decision of the Plenary Session of the Council of State No 2347-2348/2017867, which accepted that Türkiye may be designated as a safe third country for Syrian citizens. However, in view of the strong minority of 12 members, out of a total of 25, advocating at 859 860 861 862 863 864 865 866 867 2nd IAC, 171515/2023, 23 March 2023, p. 7; 8th IAC, 583703/2022, 5 October 2022, p. 12; 511455/2022, 5 September 2022, p. 19; 237130/2022, 29 April 2022, p. 16; 161054/2022, 21 March 2022, p. 13; 142176/2022, 11 March 2022, para 9; 458313/2021, 15 December 2021, para 9; 11th IAC, 71895/2022, 8 February 2022, para 13; 67923/2022, 7 February 2022, para 9; 384227/2021, 15 November 2021, para 9; 2075/2021, 26 February 2021, para 11; 2727/2020, 9 April 2020, para 10; 13th IAC, IP/113682/2023, 13 September 2023, para 11; 22148/2023, 13 January 2023, para 8; 734754/2022, 7 December 2022, para 9; 14th IAC, IP/335367/2023, 6 December 2023, p. 18; 250567/2023, 3 May 2023, p. 24; 211179/2023, 11 April 2023, p. 24; 16th IAC, 85916/2023, 10 February 2023, para IV.4; 394674/2022, 7 July 2022, p. 7; 21st IAC, 710801/2022, 28 November 2022, pp. 9-10; 690292/2022, 18 November 2022, p. 8; 467020/2021, 20 December 2021, p. 10, as cited in ProAsyl and RSA, The concept of “Safe third country”. Legal standards and Implementation in the Greek Asylum System, February 2024, available at: https://bit.ly/44fR5jV, p. 10, note 29. For example, 3rd IAC, 47496/2022, 28 January 2022, para 15; 4th IAC, 204504/2023, 7 April 2023, pp. 1819; 79499/2023, 8 February 2023, para III.2; 6th IAC, IP312088/2023, 28 November 2023, para IV.5; IP/291367/2023, 21 November 2023, para IV.5; 11th IAC, IP/578/2023, 28 June 2023, pp. 24-25; 12th IAC, 168365/2023, 7 April 2023, p. 15; 14th IAC, IP/335367/2023, 6 December 2023, p. 21; 250567/2023, 3 May 2023, p. 26; 211179/2023, 11 April 2023, pp. 25-26. 10th IAC, 22083/2020, 28 April 2021, para 2; 12540/2020, para 4; 17th IAC, 292768/2023, 8 June 2023, para 3; 21st IAC, 398486/2021, 19 November 2021, p. 20, as cited in ProAsyl and RSA, “The concept of “Safe third country”. Legal standards and Implementation in the Greek Asylum System, February 2024, available at: https://bit.ly/44fR5jV, p. 12, note 43. Exceptions include 4th IAC, 204504/2023, 7 April 2023, pp. 14 and 17; 12th IAC, 168365/2023, 22 March 2023, pp. 11 and 14; 15th IAC, IP/20208/2024, 10 January 2024, para 16, as cited in ProAsyl and RSA, “The concept of “Safe third country”. Legal standards and Implementation in the Greek Asylum System, February 2024, available at: https://bit.ly/44fR5jV, p. 10, note 29. GCR, HIAS, RSA, Greek Asylum Case Law Report Issue 1/2024, available here; GCR, HIAS, RSA, Greek Asylum Case Law Report Issue 2/2024, available here. Article 56(1)(f) L 4375/2016. Article 56(1)(f) L 4375/2016. Article 86(1)(f) IPA and 91(1)(f) of the Asylum Code. Greek Council of State, Joint decisions 2347/2017 and 2348/2017, 22 September 2017, available here. 167