Communicated on 5 August 2014
FIFTH SECTION
Application no. 10290/13
Farhiyo MAHAMED JAMA
against Malta
lodged on 4 February 2013
STATEMENT OF FACTS
The applicant, Ms Farhiyo Mahamed Jama, is a Somali national, who (to her knowledge) was born in 1996 and at the time of the introduction of the application was detained in Lyster Barracks, Hal Far. She is represented before the Court by Dr M. Camilleri and Dr K. Camilleri, lawyers practising in Valletta.
A. The circumstances of the case
The facts of the case, as submitted by the applicant, may be summarised as follows.
1. Background to the case
The applicant entered Malta in an irregular manner by boat on 27 May 2012. Upon arrival, she was registered by the immigration police, given an identification number (12H-006) and presented with two documents in English, one containing a Return Decision and the other a Removal Order.
The Return Decision stated that she was a prohibited immigrant by virtue of Article 5 of the Immigration Act (Chapter 217 of the Laws of Malta) because she was in Malta “without means of subsistence and liable to become a charge on public funds”. The Return Decision also informed the applicant that her stay was being terminated and of the possibility to apply for a period of voluntary departure. The Removal Order was based on the consideration that the applicant’s request for a period of voluntary departure had been rejected. It informed the applicant that she would remain in custody until removal was affected and that an entry ban would be issued against her. The two documents further informed the applicant of her right to appeal against the Decision and Order before the Immigration Appeals Board (“the IAB”) within three working days.
The contents of the decision in English were not explained to the applicant who could not understand the language. The applicant was further provided with an information leaflet entitled “Your entitlements, responsibilities and obligations while in detention” in Arabic, a language she did not understand.
In accordance with Article 14 (2) of the Immigration Act (see Relevant domestic law), the applicant was detained, in Lyster Barracks.
2. Initial proceedings
During the registration process upon her arrival, in the absence of an interpreter, the applicant’s age was recorded as twenty-six, however, she claims to have told the authorities that she was sixteen years old.
On 30 May 2012 the applicant appealed against the Removal Order and Return Decision. To date of the introduction of the application her appeal had not been appointed for hearing by the IAB.
3. Asylum proceedings
A few days following her arrival the applicant was called for an information session provided by the Staff of the Office of the Refugee Commissioner. She was assisted in submitting the Preliminary Questionnaire (PQ), thereby registering her wish to apply for asylum under Article 8 of the Refugees Act, Chapter 420 of the Laws of Malta (see Relevant Domestic Law, below). She stated on the form that she was sixteen years old.
4. The AWAS Age-Assessment Procedure
The applicant submitted that in spite of the fact that this procedure can have a determining impact on the continued detention of individuals detained in terms of the Immigration Act, it was not adequately regulated by law or by publicly available rules or procedures. The only reference to age assessment procedures was that in the Government’s policy document and subsidiary legislation (see Relevant domestic law below).
In practice, from the information available to the applicant, it appeared that the Age Assessment Procedure consisted of a number of different phases. Individuals were referred to the Agency for the Welfare of Asylum Seekers (AWAS) by the Immigration Police (where they declare to be minors on arrival) or the Refugee Commissioner (where they declare to be minors in their PQ). Following referral, an initial interview is conducted by one member of AWAS staff. Where this interview is inconclusive, a second interview is conducted by a panel of three persons known as the Age Assessment Team (AAT).
Where the panel is convinced that the individual concerned is not a minor, the minority age claim is rejected. Where a doubt remains, s/he is referred for a Further Age Verification (FAV) test, which essentially consists of an x-ray of the bones of the wrist. Although the AAT is not bound by the results of the test, in practice, it would appear that in most cases where it is resorted to the result will determine the outcome of the assessment.
If the individual concerned is found to be a minor, a care order is issued, the individual is released from detention and placed in an appropriate non‑custodial residential facility, and a legal guardian is appointed to represent the minor. Once a guardian is appointed the asylum interview is carried out, and during the said interview the minor is assisted by a legal guardian. If the individual’s claim to minor age is rejected, AWAS informs the Refugee Commissioner so that his Office can proceed with the refugee status determination procedure.
In the applicant’s case, on an unspecified date, some two months after her arrival in Malta, she was called for an interview with a member of AWAS staff who informed her that, as she had claimed to be sixteen years old she would be interviewed by three members of AWAS staff with a view to assessing the veracity of her claim to minor age.
About a week later, three people from AWAS interviewed her. During the interview a male detainee provided interpretation services. After the interview they informed her that as they could not confirm her minor age through the interview they would send her for a further age verification (FAV) test - i.e. an x-ray of the bones of the wrist. The applicant was taken for the FAV test about two months after her interview, on 5 October 2012.
At the beginning of November, as the applicant had not received any decision from the AAT, she asked a woman from AWAS (who was visiting the detention centre to conduct interviews with other detainees who had health problems) whether she knew anything about her case. The woman told her that her x-ray was being assessed and if she was found to be a minor she would be released soon. Some three weeks later, on 22 November 2012, some other people from AWAS went to the centre and told her that according to the test she was not a minor but an adult. During the latter meeting a fellow (female) detainee provided translation.
Until the date of the lodging of the application, the applicant had not received a written decision informing her of the outcome of the age assessment procedure.
5. Conditions of detention
The applicant was detained in Hermes Block in Lyster Barracks, in conditions which she considered prison like and basic. She explained that the Block is divided into five self-contained zones (one on the ground floor two on the first floor and two on the second floor) four of which (B,C,D,E) were virtually identical. For the first few days of her detention she had been held in Zone E which at the time accommodated families (ie. couples with or without children), and then she was moved to Zones C and D with other single women.
These zones contained a number of dormitories (containing bunk beds but no lockers or cupboards for personal belongings), ten showers and toilets, a small kitchen with one or two hot plates and a fridge (no further storage for food, which was contained in open boxes accessible to insects, was available), and a common room with six basic metal tables and benches screwed to the ground, together with a television. Blankets hanging from bunk beds were the only means of privacy.
Access to the zones was through metal gates which were kept locked all day, and detainees could leave the zone for one and a half hours per day, which they could spend in a small dusty yard. Windows were barred and most of them glazed with opaque Perspex (which was removed in the summer months for air, though they then let air through in the cold winter months). On the one hand, in summer the facility was often crowded and heat would become oppressive despite ceiling fans. On the other hand, in winter it was unbearably cold as the facility was not heated and, moreover, was exposed to the elements as there were no adjoining buildings.
The applicant considered that the facility was shared by too many people – in summer the applicant’s dormitory was shared by twenty women – and agreement amongst so many different persons having cultural and linguistic differences was difficult. However, at the time of the introduction of the application, the applicant was in less crowded conditions, sharing a zone with only twenty-five other women, most of whom were Eritrean and Somali.
The applicant noted that since her arrival she had only been provided with two bed sheets, a towel, a blanket, a T-shirt, a few items of underwear and a pair of flip-flops. In winter they were not systematically provided with warm clothes and closed shoes, which were distributed according to what was received by way of donation and which was not sufficient to supply the needs of all detainees. Although blankets were distributed to everyone, the building was not heated and winter months were unbearably cold.
Detainees had little to do all day, and only limited access to open air. In particular the applicant noted that she was let out into the small dirty yard for the first time only after a few months of detention. While in the yard, other male detainees called out names and picked on the women from the windows of their rooms overlooking the yard. The applicant referred to the report “Not here to stay: Report of the International Commission of Jurists on its visit to Malta on 26 – 30 September 2011”, May 2012, which pointed out, inter alia, that: “The ICJ delegation found a lack of leisure facilities in all three detention facilities visited. ... In the Lyster Barracks there was also a small recreation yard, but without direct access from the detention section. Detainees had two hours per day of “air” in the courtyard. They reportedly seldom received visits from outside, apart from the occasional NGO.”
She also noted that although telephone cards were distributed, the credit they contained was often insufficient to make long distance calls and no cheaper ways of keeping contact with the family or outside world were available as they had no internet access. By the time of the introduction she had received EUR 25 in credit. The applicant also considered inappropriate that detainees were given the same soap to use for their bodies, hair, clothes and floor. The applicant further made reference to an incident with a detention officer who had pushed her down the stairs and tried to forcefully resuscitate her by slapping her and grabbing different parts of her face leaving her in pain – she, however, admitted that she could not recognise such officer and that she had feared reprisal had she reported the matter.
Furthermore, as could be seen from the results of the Jesuit Refugee Service (JRS) Europe study on detention of vulnerable asylum seekers, the physical conditions of detention and their impact on the physical and mental well-being of detainees were exacerbated by other factors[1]. These factors included: length of detention, lack of constructive activities to occupy detainees, overcrowding, limited access to open air, difficulties in communication with staff and with other detainees, and lack of information about one’s situation. Moreover, there was a lack of any real possibility of obtaining effective redress and inmates knew that detention was not serving any useful purpose and was in no way proportionate to the aim to be achieved.
The applicant submitted that all of those objective factors had had a particular impact on her because of her personal circumstances, particularly her young age, her inability to communicate in anything but Somali and the fact that as a young woman she was detained in a facility administered almost exclusively by males.
6. Latest developments
On 24 January 2013 the applicant was called for an interview with the Refugee Commissioner. By means of a decision of the Refugee Commissioner of 2 February 2013, the applicant was granted subsidiary protection in Malta. She was notified of this decision and released on 7 February 2013.
B. Relevant domestic law and practice
1. The Immigration Act
Immigration and asylum procedures are mainly regulated by the Immigration Act (“the Act”), Chapter 217 of the Laws of Malta. Article 5 of the Act defines the term “prohibited immigrant” and, in so far as relevant, reads as follows:
“(1) Any person, other than one having the right of entry, or of entry and residence, or of movement or transit under the preceding Parts, may be refused entry, and if he lands or is in Malta without leave from the Principal Immigration Officer, he shall be a prohibited immigrant.
(2) Notwithstanding that he has landed or is in Malta with the leave of the Principal Immigration Officer or that he was granted a residence permit, a person shall, unless he is exempted under this Act from any of the following conditions or special rules applicable to him under the foregoing provisions of this Act, be a prohibited immigrant also -
(a) if he is unable to show that he has the means of supporting himself and his dependants (if any) or if he or any of his dependants is likely to become a charge on the public funds; or ...”
Article 10 of the Act, regarding temporary detention, in so far as relevant reads as follows:
“(1) Where leave to land is refused to any person arriving in Malta on an aircraft ...
(2) Where leave to land is refused to any person arriving in Malta by any other means, such person at his own request may, with the leave of the Principal Immigration Officer, be placed temporarily on shore and detained in some place approved by the Minister and notified by notice in the Gazette:
Provided that he shall be returned to the vessel by which he is to leave Malta immediately that he makes a request to that effect or that the Principal Immigration Officer so directs, whichever is the earlier.
(3) Any person, while he is detained under sub-article (1) or (2), shall be deemed to be in legal custody and not to have landed.”
In practice, upon being apprehended a prohibited immigrant is issued with a Removal Order, in accordance with Article 14 of the Act, which, in so far as relevant, reads as follows:
“(1) If any person is considered by the Principal Immigration Officer to be liable to removal as a prohibited immigrant under any of the provisions of article 5, the said Officer may issue a removal order against such person who shall have a right to appeal against such order in accordance with the provisions of article 25A: ...
(2) Upon such order being made, such person against whom such order is made, shall be detained in custody until he is removed from Malta:
Provided that if the person in respect of whom an expulsion order has been made is subject to criminal proceedings for a crime punishable with imprisonment or is serving a sentence of imprisonment, the Minister may give such directions as to whether the whole or part of the sentence is to be served before the expulsion of such person from Malta, and, in default of such directions, such person shall be removed after completion of the sentence.”
An “irregular” immigrant is entitled to apply for recognition of refugee status by means of an application (in the form of a Preliminary Questionnaire) to the Commissioner for Refugees within two months of arrival. While the application is being processed, in accordance with Maltese policy, the asylum seeker will remain in detention for a period up to eighteen months, which may be extended if, upon rejection of the application, he or she refuses to cooperate in respect of his or her repatriation.
Article 25A of the Act provides that an application may be made to the Immigration Appeals Board (the Board) if an asylum seeker considers that his or her detention is no longer reasonable. This entails requesting release from custody pending determination of an individual’s asylum claim or his or her deportation. The same Article regulates the manner in which, and when, such release may be granted. The relevant provisions read as follows:
“(5) Any person aggrieved by any decision of the competent authority under any regulations made under Part III, or in virtue of article 7 [residence permits], article 14 [removal orders] or article 15 [responsibility of carriers] may enter an appeal against such decision and the Board shall have jurisdiction to hear and determine such appeals.
(6) During the course of any proceedings before it, the Board may, even on a verbal request, grant provisional release to any person who is arrested or detained and is a party to proceedings before it, under such terms and conditions as it may deem fit, and the provisions of Title IV of Part II of Book Second of the Criminal Code shall, mutatis mutandis apply to such request.
(7) Any appeal has to be filed in the Registry of the Board within three working days from the decision subject to appeal: ...
(8) The decisions of the Board shall be final except with respect to points of law decided by the Board regarding decisions affecting persons as are mentioned in Part III, from which an appeal shall lie within ten days to the Court of Appeal (Inferior Jurisdiction) ...
(9) The Board shall also have jurisdiction to hear and determine applications made by persons in custody in virtue only of a deportation or removal order to be released from custody pending the determination of any application under the Refugees Act or otherwise pending their deportation in accordance with the following subarticles of this article.
(10) The Board shall only grant release from custody under subarticle (9) where in its opinion the continued detention of such person is taking into account all the circumstances of the case, unreasonable as regards duration or because there is no reasonable prospect of deportation within a reasonable time:
Provided that where a person, whose application for protection under the Refugees Act has been refused by a final decision, does not co-operate with the Principal Immigration Officer with respect to his repatriation to his country of origin or to any other country which has accepted to receive him, the Board may refuse to order that person’s release.
(11) The Board shall not grant such release in the following cases:
(a) when the identity of the applicant including his nationality has yet to be verified, in particular where the applicant has destroyed his travel or identification documents or used fraudulent documents in order to mislead the authorities;
(b) when elements on which any claim by applicant under the Refugees Act is based, have to be determined, where the determination thereof cannot be achieved in the absence of detention;
(c) where the release of the applicant could pose a threat to public security or public order.
(12) A person who has been released under the provisions of subarticles (9) to (11) may, where the Principal Immigration Officer is satisfied that there exists a reasonable prospect of deportation or that such person is not co-operating with the Principal Immigration Officer with respect to his repatriation to his country of origin or to another country which has accepted to receive him, and no proceedings under the Refugees Act are pending, be again taken into custody pending his removal from Malta.
(13) It shall be a condition of any release under subarticles (9) to (12) that the person so released shall periodically (and in no case less often than once every week) report to the immigration authorities at such intervals as the Board may determine.”
2. The Refugees Act
Article 8 of the Refugees Act, Chapter 420 of the Laws of Malta, reads as follows:
“(1) A person may apply to the Commissioner, in the prescribed form, and shall be granted refugee protection, where it is established that he faces a well-founded fear of persecution in his country of origin or habitual residence in terms of the Convention.
(2) A well-founded fear of persecution may be based on events which have taken place after applicant has left his country of origin or activities engaged in by applicant since leaving the country of origin, except when based on circumstances which the applicant has created by his own decision since leaving the country of origin.
(3) If the Commissioner recommends the acceptance of the application, the Minister shall make a declaration that applicant is eligible for refugee status, or appeal against such recommendation.”
3. Government Policy
According to the Irregular Immigrants, Refugees and Integration Policy Document, issued by the Ministry for Justice and Home Affairs and the Ministry for the Family and Social Solidarity, in 2005:
“Irregular immigrants who, by virtue of their age and/or physical condition, are considered to be vulnerable are exempt from detention and are accommodated in alternative centres”.
The document contains an inclusive list of those categories of migrants considered vulnerable, which includes: “unaccompanied minors, persons with disability, families and pregnant women”. With specific reference to unaccompanied minors and age assessment, the policy document states that:
“Unaccompanied children and minors will be placed under state custody in terms of the Children and Young Persons (Care Order) Act (Chapter 285). This ensures that an unaccompanied minor is given the same treatment as a Maltese minor. ... The detention of minors should be no longer than what is absolutely necessary to determine their identification and health status. Interviews are to be carried in a ‘child friendly’ manner.
Unfortunately there will be cases where individuals make false claims about their age in order to benefit from the terms and conditions of a Care Order. In order to ensure, as far as possible, that:
(a) Care Orders are only issued in respect of true minors;
(b) provisions for minors are not abused, and
(c) actual minors are not deprived of the accommodation and services to which they are entitled by virtue of their age and the degree of vulnerability associated with it, Ministry for Justice and Home Affairs in consultation with the Ministry for the Family and Social Solidarity shall, in those cases where there is good reason to suspect the veracity of the minority age claimed by the immigrant, require the individual concerned to undertake an age verification test as soon as possible after arrival”.
4. The Age Assessment Procedure
In order to give effect to this policy, a procedure known as the Age Assessment Procedure was developed and implemented first by the Refugee Service Area within Aġenzija Appoġġ (the National Agency for children, families and the community) and later by AWAS (formerly OIWAS), with a view to assessing claims to minor age. Although AWAS is not formally charged with the responsibility for this procedure by the law which constitutes it (see below) in practice the said agency has full responsibility for this procedure.
In so far as relevant, Regulation 6 of the Agency for the Welfare of Asylum Seekers Regulation, Subsidiary Legislation 217.11, reads as follows:
“(1) The function of the Agency shall be the implementation of national legislation and policy concerning the welfare of refugees, persons enjoying international protection and asylum seekers.
(2) In the performance of its functions, the Agency shall:
(a) oversee the daily management of accommodation facilities either directly or through subcontracting agreements;
(b) provide particular services to categories of persons identified as vulnerable according to current policies;
(c) provide information programmes to its clients in the areas of employment, housing, education, health and welfare services offered under national schemes;
(d) act as facilitator with all public entities responsible for providing services to ensure that national obligations to refugees and asylum seekers are accessible;
(e) promote the Government’s policy and schemes regarding resettlement and assisted voluntary returns;
(f) maintain data and draw up reports that are considered relevant for its own function and to provide statistics to appropriate policy-making bodies;
(g) advice the Minister on new developments in its field of operation and propose policy or legislation required to improve the service given and fulfil any legal obligations in respect of its service users;
(h) encourage networking with local voluntary organisations so as to increase the service standards as well as academic research;
(i) work with other public stakeholders and, where possible, offer its services to asylum seekers accommodated in other reception centres not under its direct responsibility; and
(j) implement such other duties as may be assigned to it by the Minister or his representative.”
Regulation 15 of the Procedural Standards in Examining Applications for Refugee Status Regulations Subsidiary Legislation 420.07 - Legal Notice 243 of 2008, lays down some basic procedural safeguards applicable when minors are interviewed, including the provision of information about the asylum procedure, assistance with preparation for the interview and presence of the representative during the interview.
Regulation 15 (2) deals with the use of medical procedures to determine age within the context of an application for asylum.
Article 15 of the Reception of Asylum Seekers (Minimum Standards) Regulations, Subsidiary Legislation 420.06 – Legal Notice 320 of 2005, states that:
“an unaccompanied minor aged sixteen years or over may be placed in accommodation centres for adult asylum seekers”.
5. Other Relevant Subsidiary Legislation
Part IV of Subsidiary Legislation 217.12, Common Standards and Procedures for Returning Illegally Staying Third-Country Nationals Regulations, Legal Notice 81 of 2011 (Transposing Directive 2008/115/EC of the European Parliament and of the Council of 16 December 2008 on common standards and procedures in member States for returning illegally staying third-country nationals) reads, in so far as relevant, as follows:
Regulation 11
“(1) The provisions of Part IV shall not apply to third country nationals who are subject to a refusal of entry in accordance with Article 13 of the Schengen Borders Code or who are apprehended or intercepted by the competent authorities in connection with the irregular crossing by sea or air of the external border of Malta and who have not subsequently obtained an authorisation or a right to stay in Malta.
(2) A return decision, an entry-ban decision and a removal order shall be issued in writing and shall contain reasons in fact and in law and information on legal remedies:
Provided that the reasons in fact may be given in a restrictive way where the withholding of information is regulated by law, in particular where the disclosure of information endangers national security, public policy, and the prevention, detection, investigation and prosecution of criminal offences.
(3) A return decision shall be issued in a standard form and general information as regards such form shall be given in at least five languages which third-country nationals may reasonably be supposed to understand.
(4) The Board shall review decisions related to return on application by the third-country national as referred to in subregulation (2), and may temporarily suspend their enforcement.
(5) For the purposes of sub-regulation (4) a legal adviser shall be allowed to assist the third-country national and, where entitled to, free legal aid shall be provided to the third-country national.
(6) The Principal Immigration Officer shall provide, upon request, a written or oral translation of the main elements of a return decision and information on the legal remedies in a language the third-country national may reasonably be supposed to understand. ...
(8) Where a third-country national is the subject of return procedures, unless other sufficient and less coercive measures are applicable, the Principal Immigration Officer may only keep him in detention in order to carry out the return and removal procedure, in particular where:
(a) there is a risk of absconding; or
(b) the third-country national avoids or hinders the return or removal procedure:
Provided that the detention shall be for a short period and shall subsist as long as the removal procedure is in progress and is executed with due diligence.
(9) Detention shall be a consequence of the removal order issued by the Principal Immigration Officer and it shall contain reasons in fact and in law.
(10) The third-country national subject to the provisions of sub-regulation (8) shall be entitled to institute proceedings before the Board to contest the lawfulness of detention and such proceedings shall be subject to a speedy judicial review.
(11) Where the third-country national is entitled to institute proceedings as provided in sub-regulation (10) he shall immediately be informed about such proceedings.
(12) The third country-national shall be immediately released from detention where in the opinion of the Board such detention is not lawful.”
Sub-regulation (8) referred to in this article reads as follows:
“Where a third-country national is the subject of return procedures, unless other sufficient and less coercive measures are applicable, the Principal Immigration Officer may only keep him in detention in order to carry out the return and removal procedure, in particular where:
(a) there is a risk of absconding; or
(b) the third-country national avoids or hinders the return or removal procedure:
Provided that the detention shall be for a short period and shall subsist as long as the removal procedure is in progress and is executed with due diligence.”
COMPLAINTS
The applicant complains under Article 3 in respect of the conditions of her detention, noting in particular the lack of access to constructive or recreational activities, insufficient provision of basic needs, lack of information, difficulties communicating with the outside world, limited access to open air and obstacles in obtaining the most basic services. Other factors which had to be taken into consideration were her young age, her inability to communicate in English, and the fact that the detention centre was staffed exclusively by men despite her being a young female.
The applicant also complains under Article 5 § 1 that her continued detention for more than eight months was arbitrary and unlawful, as it did not fall under either of the two limbs under the mentioned provision. In any event the law was not precise and did not provide for procedural safeguards. Moreover, her continued detention could not be considered reasonably required for the purpose, nor closely connected to the purpose of preventing an unauthorised entry. Furthermore she had been detained in conditions which were not appropriate for a young single asylum seeker.
The applicant complains under Article 5 § 2 that the Return Decision and Removal Order, provided to her in English, a language she did not understand, did not contain sufficient information enabling her to challenge her detention.
The applicant further complains that she did not have a remedy which met the requirements of Article 5 § 4, as outlined in the Court’s jurisprudence, to challenge the lawfulness of her detention.
QUESTIONS TO THE PARTIES
1. Did the conditions of the detention facility, namely Lyster Barracks in each of the Zones in which the applicant had been detained, amount to inhuman and degrading treatment contrary to Article 3?
2. Was the applicant deprived of her liberty in breach of Article 5 § 1 of the Convention? In particular, did the deprivation of liberty, suffered by the applicant fall within any paragraph of this provision?
In so far as that period of detention (or part thereof) may have been effected for the purposes of the first limb of Article 5 § 1 (f), i.e. “to prevent effecting an unauthorised entry into the country”, was the detention lawful in terms of domestic law and free from arbitrariness in the context of the first limb of Article 5 § 1 (f), namely was the applicant’s detention compatible with that provision, and in particular given the duration of the age assessment procedure was it closely connected to the ground of detention relied on (see Saadi v. the United Kingdom [GC], no. 13229/03, § 77 ECHR 2008 and Suso Musa v. Malta, no. 42337/12, 23 July 2013)?
In relation to the period following the grant of subsidiary protection, namely 2 February to 7 February 2013, did that deprivation of liberty, fall within any paragraph of this provision (see, mutatis mutandis, Labita v. Italy [GC], no. 26772/95, § 173, ECHR 2000‑IV)?
3. Was the applicant informed promptly, in a language which she understood, of the reasons for her detention under Article 5 § 1 as required by Article 5 § 2 of the Convention?
4. Was the applicant able to bring proceedings which complied with Article 5 § 4 of the Convention to challenge the lawfulness of her detention?
[1] Becoming Vulnerable in Detention, National Report on Malta, July 2010, which may be accessed at: last accessed on 20 June 2014.
The Regional Report on the DEVAS project, published by JRS Europe in June 2010 may no longer be accessed online.
Full & Egal Universal Law Academy