temporary protection status upon return is sufficient in itself to establish a connection between the applicant and Türkiye, even in cases of very short stays and in the absence of other links. 871 The Appeals Committees considers that the connection criteria can be established by taking into consideration inter alia the “large number of persons of the same ethnicity” living in Türkiye; the “free will and choice” of the applicants to leave Türkiye and “not organise their lives in Türkiye”; “ethnic and/or cultural bonds” without further specification; the proximity of Türkiye to Syria; and the presence of relatives or friends in Türkiye without an effective examination of their status and situation there. Additionally, in line with the 2017 rulings of the Council of State, 872 transit from a third country, in conjunction with inter alia the length of stay in that country or the proximity of that country to the country of origin, is also considered in second instance decisions as sufficient for the fulfilment of the connection criteria. It should be recalled that in the case presented before the Council of State where the Court found that the connection criteria were fulfilled, that applicants had stayed in Türkiye for periods of one and a half month and one month respectively. Greek courts have clarified that such an assessment cannot be limited to mere reference to the number of refugees present in the country or the duration of the person’s stay prior to arrival in Greece. 873 Yet asylum authorities at both first and second instance frequently use a standard text concluding on the existence of a connection between an applicant and Türkiye, without having conducted any individualised assessment of their personal circumstances. Other decisions adopt widely diverging and at times too broad interpretations of factors that may establish a sufficient connection. 874 3. First country of asylum The “first country of asylum” concept is a ground for inadmissibility (see Admissibility Procedure and FastTrack Border Procedure). According to Article 90 Asylum Code, a country shall be considered to be a “first country of asylum” for an applicant provided that they will be readmitted to that country, if the applicant has been recognised as a refugee in that country and can still enjoy that protection or enjoys other effective protection in that country, including with regards to the principle of non-refoulement. The “first country of asylum” concept is not applied as a stand-alone inadmissibility ground in practice. 871 872 873 874 Note that the decision refers to the applicant’s ‘right to request an international protection status’, even though persons under temporary protection are barred from applying for international protection, see AIDA, Country Report: Türkiye, 2017 Update, March 2018, available at: https://bit.ly/4aP9k23, p. 125. Council of State, Decision 2347/2017, 22 September 2017, para 62; Decision 2348/2017, 22 September 2017, para 62. Note the dissenting opinion of the Vice-President of the court, stating that transit alone cannot be considered a connection, since there was no voluntary stay for a significant period of time. See also EDAL, Greek Council of State, Decision no 2347/2017, 22 September 2017, available at: https://bit.ly/3QibK0Z; EDAL, Greek Council of State on Turkey as a safe third country and aspects of the Greek Asylum procedure, 22 September 20177, available at: https://bit.ly/3UcgPJd; Joint decisions 2347/2017 and 2348/2017, 2347/2017 and 2348/201, Greece: Council of State, 22 September 2017, https://bit.ly/44uHAxr. GCR, HIAS, RSA, Greek Asylum Case Law Report Issue 2/2024, 9 η ΕπΠροσ ΙΡ/129467/2024 . 9 η ΕπΠροσ ΙΡ/129654/2024 , both available in Greek here. For example, 1st IAC, 310227/2022, 1 June 2022, para 4.3; 6th IAC, 5892/2020, 27 May 2020, p. 25; 8th IAC, 103648/2023, 20 February 2023, pp. 8-9; 142176/2022, 11 March 2022, para 10; 458313/2021, 15 December 2021, para 10; 9th IAC, 288224/2021, 4 October 2021, p. 11; 13th IAC, IP/113682/2023, 13 September 2023, para 12; 22148/2023, 13 January 2023, para 9; 734754/2022, 7 December 2022, para 10; 14th IAC, IP/335367/2023, 6 December 2023, p. 23; 250567/2023, 3 May 2023, p. 28; 211179/2023, 11 April 2023, p. 28; 18th IAC, 672919/2022, 11 November 2022, p. 7; 165716/2021, 3 August 2021, p. 7; 165163/2021, 3 August 2021, p. 8; 68486/2021, 16 June 2021, p. 6; 19th IAC, 73674/2022, 8 February 2022, p. 18; 73459/2022, 8 February 2022, p. 12. 169