Interventions

Safe' countries and European legislation

4' min read

4' min read

In Italy, justice and politics really do seem to be two prerogatives that are now irreconcilable with each other. As if, for our Constitution, the judiciary were a counter-power to politics and the legislature and not the expression of a balance between these institutional powers, based on the observance of their respective competences. And now, in the middle, there is also the European judiciary - whose magistrates, ironically, wear vermilion togas - which, according to Palazzo Chigi, is not responsible for making decisions on which countries are safe, as these are the exclusive competence of the legislative or governmental authorities of each member state. On the other hand, to sing victory by a part of the judiciary (of the type: 'we were right') also seems out of place.

Be that as it may, a preliminary ruling by the EU Court of Justice has neither winners nor losers, precisely because it interprets EU law and not that of a Member State. On the other hand, the fact that the Italian courts' preliminary questions were very delicate and relevant, not only for Italy but for many other Member States, is proven by the fact that no less than 17 governments intervened in the case.

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The interpretative ruling in question was therefore eagerly awaited in judicial, legislative and governmental circles halfway across Europe (for a summary of the facts of the case see, Il Sole24ore of 1 August)

In the limited editorial space of a commentary on a complex interpretative ruling such as this one, it is therefore necessary to set aside partisan polemics and instead deal with a few fundamental aspects, which are helpful in dispelling important misunderstandings.

First, let us clarify the legal framework. It is composed of three distinct layers of law; the provisions of the Lisbon Treaty (primary Union law); those of the European legislator (secondary European law) and, finally, the national legislative or administrative provisions, i.e. national implementing law. When exercising their respective competences, the European and national legislators must therefore respect primary Union law. For example, Article 47 of the Charter of Fundamental Rights of the Union, cited several times in requests for referral to the Court, provides that 'everyone whose rights and freedoms guaranteed by the law of the Union have been infringed shall have an effective remedy before a court or tribunal'. Now, Article 19 of this same Charter provides that 'no one shall be removed to a State where there is a serious risk ... of being subjected ... to inhuman or degrading treatment'.

This is, of course, a right of the individual but also an inescapable obligation for the competent authorities. On the other hand, Article 78 TFEU, on the subject of border control, specifies that 'the Union shall develop a ... protection policy ... aimed at offering appropriate status to any third-country national requiring international protection and at ensuring compliance with the principle of non-refoulement'.

And it is precisely with respect to these provisions that the Italian misunderstanding arises as to who is to decide which third countries are safe. Sovereign states 'designate' safe countries but do not 'force' judges to automatically reject the illegal immigrant from a safe country. In fact, every illegal immigrant must have the full right, before being returned, to have it ascertained that his or her personal situation is adequately safeguarded in his or her country of origin with respect, in particular, to the fundamental right to human dignity enshrined in Article 1 of the Charter. This unconditional right of every person was also referred to by our Constitutional Court in its recent judgment 96/25 of 3 July. In that judgment, the Constitutional Court recalled that "the mortification of human dignity that occurs in every instance of physical subjection to the power of others ... is a sure indication of the relevance of the measure to the sphere of personal freedom". In short, in matters of international protection of illegal immigrants, the Member States are not the undisputed and exclusive masters of the national security level of the corresponding third States.

Having said that, the real novelty of the judgment lies in the requirement, incumbent on the national authorities, to ensure that the applicant and the court seized have access to all sources of information and documentation used by those authorities in ordering the rejection of the application for international protection. While there are many important consequences flowing from this obligation, the most immediate one, as far as these authorities are concerned, is that they can no longer limit themselves to stating the reasons for their decision but must also accompany and corroborate it with the relevant sources of information, so as to ensure that the individual has an effective judicial remedy and the judge has adequate knowledge of all the elements of the case.

Ultimately, beyond sterile partisan polemics, the Court's ruling clearly states that at the heart of current EU and Member State legislation on immigration is, on the one hand, the individual, with all his or her rights, and, on the other, respect for the fundamental principle of the rule of law.

*Judge at the General Court of the European Union

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