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 legislation802 as to the connections considered “reasonable” between an applicant and a third country,803 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:804 (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 2347-2348/2017, 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 for the referral of a preliminary question to the Court of Justice of the European Union, this judgment cannot be regarded as a reliable case-law, be it at the national, European or international level, which would justify transposing it into Greek law. It should be noted that among the issues raised in the Plenary Session, the issue of the applicant's safe connection with the third country was of particular concern as well as whether the applicant's simple transit through that country was sufficient in this respect, in combination with certain circumstances, such as the duration of their stay there and the proximity to their country of origin. The compatibility of Article 91(1)(f) Asylum Code with the EU acquis should be further assessed, in particular taking into consideration the CJEU Decision in case C-564/18 of 19 March 2020, in which the Court ruled that “the transit of the applicant from a third country cannot constitute as such a valid ground in order to be considered that the applicant could reasonably return in this country”. It is worth noting that, since October 2021, applications for international protection of asylum seekers originating from Syria, Afghanistan, Pakistan, Bangladesh and Somalia are deemed admissible if a period of more than one year has elapsed since the applicants’ transit from the third country and the applicants have not maintained relations (economic, social, etc.) with that country during that period. Hence, it is considered that the precondition of the link as per Article 91(1)(f) of the Asylum Code is no longer fulfilled and as such it would be not reasonable for the applicants to return to that country. The aforementioned admissibility decisions are based on internal Guidelines of the Asylum Service issued in October 2021, which have nevertheless not been made public to date. As regards subsequent applications lodged upon rejection of a first application on safe third country grounds, the Ministry of Migration and Asylum issued a Circular on 6 July 2021, as per which: ‘Specifically, for those applicants entering from Türkiye, the invocation of new and substantial elements must relate exclusively as foreseen in the law and the EU-Türkiye Joint Statement, to the finding on the initial application as to whether Türkiye – as the country of transit of the applicant – is safe or not for them in accordance with the national and European legislation. In the absence of any new and substantial elements as provided above, the subsequent application shall be rejected by the competent examination authorities as inadmissible, in accordance with [Article 94(4) of the Asylum Code].” According to the above 802 803 804 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. 166