administrative court accepted this argument in this particular case, it has repeatedly rejected this argument in cases that have been brought before it since. In the two cases that were rejected, the decisions were poorly reasoned and failed to address our lawyers’ main arguments. In addition to objections against detention, several other extra or non-legal remedies are available to lawyers and persons detained on Kos. First, lawyers on Kos have had varying success with a procedure known as ‘interventions.’ This is a non-legal procedure that involves lawyers submitting a request for release directly to the police, generally based on the person’s vulnerability. However, because this is a non-legal remedy any decision is at the complete discretion of the police and there is no way to appeal a negative response. Secondly, people can submit a complaint to the Greek Ombudsman. However, the Ombudsman’s recommendations are similarly not legally binding. In July 2021, Equal Rights submitted a complaint to the Greek Ombudsman on behalf of 19 rejected asylum seekers detained in the PRDC with no possibility of return to Turkey. The Ombudsman issued three opinions requesting the authorities to “reconsider the decision of administrative detention” in all 19 cases.188 However, the police have so far refused to follow the Ombudsman’s order; at the time this report was published the majority of the 19 applicants were still in detention. Finally, people detained in the PRDC and can submit their claim to the ECtHR, usually based on alleged violations of Article 3 and 5. However, this remedy is not only prohibitive to people without knowledge of the ECHR and its complicated filing procedure, but is also not a realistic means of release, as it can take years to get a final decision. Practically speaking, none of the remedies mentioned above are available to non-Greek or non-English speakers. In other words, without legal aid, these remedies are all but non-existent for the vast majority of people in the PRDC. 4. Conclusions a. Formal Procedures The above data clearly establishes that the procedural safeguards laid out in the APD and RD are not met for people detained in the Kos PRDC in numerous respects. First, there is a complete lack of information regarding the asylum procedures and people’s procedural rights, and, where information is provided by the police, oftentimes it is provided exclusively in Greek. This is in direct conflict with both Article 8 and 19 APD, which require that the authorities provide some amount of information to asylum seekers about the procedures. Further, reports from clients that the police often fail to honour their requests for legal assistance similarly conflicts with Article 71 IPA, particularly in cases where people ask for a lawyer for their appeals. Finally, contrary to the guarantees under Greek, EU, and human rights law, detainees generally have no knowledge of why they are detained and, even if they do receive copies of their detention orders, they are written in Greek and the police generally do not provide any translation. According to our research, detention orders do not contain any individualised assessment. The specific grounds for detention outlined in Article 8 (2) RCD, Article 46 Law 4636/2019 and Article 15 (1), (6), Article 30 (1), (6) Law 3907/2011 are not assessed adequately. Instead, administrative decisions mainly concern a mere repetition of the legal provisions. This automatic application of detention is contrary to Article 8 (2) RCD, Article 46 (2) Law 4636/2019 and Article 15 (1) RD, Article 30 (1) Law 3907/2011 as well as both limbs of Article 5 § 1 (f) ECHR. Given that we have never seen an individualised detention order, the current 188 Equal Rights Beyond Borders, Greek Ombudsman calls for Release of 19 Persons who are Unlawfully Detained in the Pre-Removal Detention Centre on Kos (3 August 2021), available at: https://bit.ly/3BPvn6X. 31 DETENTION OF MIGRANTS ON THE ISLAND OF KOS