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22/09/2025
CH: The Federal Administrative Court dismissed the appeal of an Ivorian applicant, finding her account of forced marriage and domestic abuse unsubstantiated and holding that the alleged acts did not amount to persecution under Article 3 of the Asylum Act, that effective state protection was available in Côte d’Ivoire, and that no humanitarian grounds justified suspension of removal.
22/09/2025
CH: The Federal Administrative Court dismissed the appeal of an Ivorian applicant, finding her account of forced marriage and domestic abuse unsubstantiated and holding that the alleged acts did not amount to persecution under Article 3 of the Asylum Act, that effective state protection was available in Côte d’Ivoire, and that no humanitarian grounds justified suspension of removal.

ECLI
Input Provided By
EUAA Grants
Other Source/Information
Type
Judgment
Original Documents
Relevant Legislative Provisions
European Convention on Human Rights (ECHR)
Reference
Switzerland, Federal Administrative Court [Bundesverwaltungsgericht - Tribunal administratif fédéral - FAC], A. v State Secretariat for Migration (Staatssekretariat für Migration‚ SEM), E-6065/2025, 22 September 2025. 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=5469
Case history
Other information
Abstract

A., a national of Côte d’Ivoire, applied for international protection in Switzerland on 7 August 2023. She claimed that, at the age of 15, her father had forced her to marry an older man to settle a debt. During the four-year marriage, she alleged that her husband repeatedly beat and raped her, and that after several escape attempts her father mistreated her and returned her to the marital home where she continued to suffer abuse. She bore two children during that time. Assisted by her mother, she eventually fled, first to Tunisia, where she worked as a cleaner for two years, and then to Italy and Switzerland with a new partner. The applicant claimed that she had had no contact with her husband since her departure, but that she knew he had remarried.  


The State Secretariat for Migration (SEM) rejected her asylum request on 15 July 2025 and ordered her removal, finding that her story lacked credibility and that she had not substantiated key details such as the identity of her husband, the circumstances of the forced marriage, or her means of departure from Côte d’Ivoire. The applicant appealed to the Federal Administrative Court on 12 August 2025, requesting refugee status, or alternatively provisional admission, and presenting a medical report dated 14 August 2025 diagnosing post-traumatic stress disorder and bilateral hydrosalpinx. 


The Federal Administrative Court found the applicant’s narrative resembled a stereotyped version of domestic violence stories rather than a personal experience. It deemed her account vague, generic, and internally inconsistent, particularly her description of her husband—referred to only as “the gentleman”—and her inability to provide verifiable details about locations, dates, or witnesses. The court also considered it unconvincing that she did not seek help from relatives earlier, especially from her mother’s side of the family. The court further noted that even if the grounds advanced by the applicant were considered plausible, she had not demonstrated persecution attributable to the State or beyond its control. She could have relocated within Côte d’Ivoire or requested protection from local authorities, which the court considered capable of intervening in cases of forced marriage or domestic violence. Regarding the applicant’s medical conditions, the court ruled that, health conditions and psychological trauma, while relevant for humanitarian protection, do not confer refugee status. 


On the enforceability of removal, the court held that Côte d’Ivoire does not present generalized violence or conditions contrary to Article 3 of the European Convention on Human Rights, and that the applicant could reintegrate with the support of her parents and siblings, who remained in the country. Her medical diagnosis did not preclude return because adequate treatment was available locally. 


In conclusion, the Federal Administrative Court dismissed the appeal, upheld the SEM’s decision and deemed removal of the applicant lawful and reasonable, stating that no humanitarian grounds justified suspension.  


Country of Decision
Switzerland
Court Name
CH: Federal Administrative Court [Bundesverwaltungsgericht - Tribunal administratif fédéral - FAC]
Case Number
E-6065/2025
Date of Decision
22/09/2025
Country of Origin
Côte d'Ivoire
Keywords
Assessment of evidence/assessment of documents
Country of Origin Information
Credibility
Gender based persecution
Internal protection alternative/ flight alternative
Medical condition
RETURN