Skip Ribbon Commands
Skip to main content
17/10/2024
The CJEU clarified that both administrative and judicial authorities have to ensure compliance with the principle of non-refoulement when deciding on a residence permit and on the enforcement of a return decision respectively.

ECLI
ECLI:EU:C:2024:892
Input Provided By
EUAA Information and Analysis Sector (IAS)
Other Source/Information
Type
Judgment
Original Documents
Relevant Legislative Provisions
EU Charter of Fundamental Rights (EU Charter); Return Directive (Directive 2008/115/EC of 16 December 2008 on common standards and procedures in Member States for returning illegally staying third-country nationals)
Reference
European Union, Court of Justice of the European Union [CJEU], K, L, M, N v State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid), C-156/23, ECLI:EU:C:2024:892, 17 October 2024. Link redirects to the English summary in the EUAA Case Law Database.
Permanent link to the case
https://caselaw.euaa.europa.eu/pages/viewcaselaw.aspx?CaseLawID=4594
Case history

Netherlands, Court of The Hague [Rechtbank Den Haag], K, L,M,N v State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid), 13 March 2023.

Other information
Abstract

The case concerned a request for a preliminary ruling submitted by the Court of the Hague seated in Roermond, on the interpretation of the EU Charter and the Return Directive - K,L,M,N v State Secretary for Justice and Security (Staatssecretaris van Justitie en Veiligheid), 13 March 2023. 


The case concerned the lawfulness of a decision rejecting the application for a residence permit provided by Dutch law and finding that the applicant's residence in the Netherlands was illegal. Consequently, the case also concerned the enforcement of a return decision previously adopted in a procedure for international protection.


The court concluded that:


1.      Article 5 of the Return Directive, read in conjunction with Article 19(2) of the EU Charter, must be interpreted as requiring an administrative authority which rejects an application for a residence permit based on national law and, consequently, finds that the third-country national concerned is staying illegally on the territory of the Member State in question, to ensure compliance with the principle of non-refoulement, by reviewing, in the light of that principle, the return decision previously adopted against that national in the context of a procedure for international protection, the suspension of which came to an end following such a rejection.


2.      Article 13(1) and (2) of the Return Directive, read in conjunction with Article 5 of that directive and with Article 19(2) and Article 47 of the EU Charter, must be interpreted as requiring a national court which is requested to review the legality of an act whereby the competent national authority has rejected an application for a residence permit provided for by national law, and, in so doing, has brought to an end the suspension of the enforcement of a return decision previously adopted in the context of a procedure for international protection, to raise of its own motion any infringement of the principle of non-refoulement resulting from the enforcement of the latter decision, on the basis of the material in the file brought to its attention, as supplemented or clarified following adversarial proceedings.


Country of Decision
European Union
Court Name
EU: Court of Justice of the European Union [CJEU]
Case Number
C-156/23
Date of Decision
17/10/2024
Country of Origin
Keywords
Assessment of Application
Non-refoulement
Return/Removal/Deportation
Appeal / Second instance determination
Suspensive effect