had existed.”146 However, the applicant had failed to provide prima facie evidence of his presence in Greece and of his personal “pushback” to Türkiye from the island of Samos on the alleged dates. Therefore, the Court underlined that the existence of a systematic practice of pushbacks does not exempt an applicant from the obligation to provide prima facie evidence to substantiate his or her allegations. In July 2022, the ECtHR issued its long-awaited landmark judgment in the case of Safi and others v. Greece (also known as the “Farmakonisi case”),147 which was supported by GCR, Refugee Support Aegean with the support of Pro Asyl, the Network of Social Support of Refugees and Immigrants, the Lawyers’ Group for the rights of Refugees and Immigrants and the Hellenic League for Human Rights. The case concerned the sinking of a fishing boat transporting 27 foreign nationals in the Aegean Sea in January 2014 off the island of Farmakonisi, resulting in the death of 11 people. According to the allegations of the applicants, the coastguard vessel was towing the fishing boat at very high speed in order to push the refugees back towards Turkish water, which caused the fishing boat to capsize, which the Greek Authorities denies. The Strasbourg Court found a violation of the right to life, both due to the authorities’ failure to investigate such a significant case responsibly and effectively, and on account of actions that they should and could have taken to protect human lives and prevent the tragic incident. The Court also held that Coast Guard officers had inflicted degrading and inhuman treatment against shipwreck survivors that night. The judgment of ECtHR ‘vindicates the victims by awarding compensation from the Greek State and brings to light an issue systematically concealed in public discourse: push backs and systematic deterrence practices which put lives at risk on a daily basis in Evros and the Aegean’.148 Forensic Architecture reported more than 2,000 pushback incidents149 on their dedicated platform, 150 which allegedly occurred from 2020 to 2023 on the Greek islands, 151 connected to 55,445 victims of pushbacks. Among them, 24 persons were reported as dead and 17 as missing. In January 2025, Aegean Boat Report (ABR) published its annual report covering the year 2024, 152 according to which 1,639 boats carrying 48,761 people arrived on the Greek islands in 2024. According to the same report, in 2024, 2,367 boats carrying 62,924 people were stopped by the Turkish Coast Guard and Police. According to ABR:153 [i]n 2024, Boats arriving has increased 13% compared to 2023, when 1.451 boats arrived, carrying 38.993 people. 14.482 people has been illegally pushed back by Greek authorities”. ABR further states that “in 2024, Aegean Boat Report have registered 508 pushback cases in the Aegean Sea, involving 14.482 children, women and men who tried to reach safety in Europe. 40.6%, 5.882 people, had already arrived on Greek territory, arrested, forced back to sea and left drifting in life rafts, illegally deported by the Hellenic Coast Guard(HCG), on orders from the Greek government, so far there has been no reaction from the EU on these illegal actions. 21.5% of all boats/rafts picked up by Turkish coast guard in 2024 had been pushed back by Greek authorities. On 19 May 2023, the New York Times (NYT) published video footages of an alleged pushback from the island of Lesvos, which allegedly took place in the midday hours of 11 April 2023. 154 Amongst others, EU 146 147 148 149 150 151 152 153 154 ECtHR, G.R.J. v. Greece (Application no. 15067/21), paras 190 and 225, available at: https://hudoc.echr.coe.int/fre?i=001-240283. Unofficial translation to English “190. Having regard to the significant number, variety and concordance of the relevant sources, the Court concludes that there are strong indications to suggest that, at the time of the events alleged, there was a systematic practice of “pushbacks” of third-country nationals, by the Greek authorities, from the greek islands to Türkiye […] 225. The Court recalls that there are serious indications that, at the material time of the alleged facts, there was a systematic practice of refoulement from the Greek islands to Türkiye”. ECtHR, Safi and others v. Greece, application no 5418/15, 7 July 2022, available at: https://bit.ly/45oTicG Press Conference: Judgement from the European Court of Human Rights in Safi and Others v Greece (Farmakonisi), Written on 07/07/2022 with a short summary of the case, available at: https://bit.ly/3OzXBfA and GCR, Vindication by the ECHR for Farmakonisi: Press conference on Monday, 11 July 2022, available at: https://bit.ly/3q61nmD. Efyn, Forensic Architecture/Forensis, Μεγάλη αύξηση των επαναπροωθήσεων μέσα σε έναν χρόνο, 19 January 2024, available at: https://bit.ly/3xodhvA. Forensic Architecture, platform available at: https://bit.ly/41W0slW and https://bit.ly/4d3kSAn. Article (in Greek) published on 15.7.2022 in ‘Ethnos’, Πασχάλης Γαγάνης, Έρευνα Forensic Architecture: Πάνω από 1.000 επαναπροωθήσεις στο Αιγαίο σε 2 χρόνια - «Ξυλοδαρμοί, κλοπές ακόμα και ρίψη στη θάλασσα με χειροπέδες», available (in Greek) at: https://bit.ly/3MRg9Xm. Aegean Boat Report, Annual Report 2024, available here. Ibid. The New York Times, ‘Greece Says It Doesn’t Ditch Migrants at Sea. It Was Caught in the Act.’, 19 May 2023, available here. 49