>> Kayahan Cantekin: Welcome, everyone. Today we will explore the laws governing the grant of asylum in Turkey. We will look broadly at the structure of the legal framework, the organization of the administration that enforces this framework and the judicial procedure that reviews the administrative process. And if we have time, we will also talk about some certain not-ideal practices in the electric in the literature that I have come across when I was doing this research, and also, I want to share certain tips for research which I think might be important for a researcher that is -- wants to start a project in this field. So just to provide some backgrounds. In this table, you can see the number of registered asylum seekers and asylees and Turkey. The data is from the UN High Commissioner of Refugees 2021, mid-statistical -- midyear statistical report, so the numbers are probably higher. It is estimated that there they are maybe more than 4 million Syrians. 3.7 is the registered number, so there probably are more who are not registered [inaudible]. There are more than 300,000 are from other [inaudible]. Even with the official figures, Turkey is hosting more refugees than any country in the world. So one particular feature that you must know to understand how the Turkish international protection system works is this geographical limitation that Turkey has to the 1951 Refugee Convention. Turkey is party to both the 1951 Refugee Convention and its 1967 protocol, and the origin convention, a lot of countries, parties to the convention to limits the scope of the definition of refugee to persons who are escaping from events occurring in Europe, and Turkey was one of the very few countries who opted to limit the scope of the definition of refugee to events occurring in Europe, and Turkey retained this this geographical limitation when it became party to the 1967 protocol. Under the the law on foreigners and international protection, this is the main law that governs the asylum system in Turkey, the LFIP. Events occurring in Europe or the term Europe is defined as member states of the Council of Europe and other states that the President may determine. In practice, it is the countries of the Council of Europe. So as I said, the main legislation that governs this whole system is the LFIP, and we will go over the whole legal framework soon. Now I just want to introduce the types of protection that exist in the system. Now there are four types of protection. Number one -- let me see if I can turn on my pointer here. Does it work? Yes. So refugee is basically it's the same definition that exists in the in the convention, persons who have a well-founded fear of being prosecuted on the basis of nationality, race, religion, membership of a particular social group or political opinion, and because of this fear, they're unable or unwilling to return to their countries of nationality or habitual residence, but this definition is limited to persons who are coming from Europe because of the geographical limitation. Now Turkey has this another type of protection, conditional refugee, that applies to the exact same definition of people but who are not coming from a European country but from any other country. The reason this is conditional is that Turkey undertakes to protect these people on the condition that they will be eventually resettled to another third country. Subsidiary protection applies to people who do not fall under the definition of refugee or conditional refugee but in the case of their return to their country of origin, they might face the death penalty or inhuman or degrading punishment or arbitrary or widespread violence like a war. The temporary protection is a special type of protection that was designed as a special status to be given to persons who came to Turkey as part of a mass population movement to claim asylum. At the time of the enactment of the LFIP, the Syrian refugee situation, because of the Syrian Civil War, was already a crisis, but Turkey had a history of dealing with mass population movements. For example, hundreds of thousands of mostly Kurdish migrants and asylum seekers from northern Iraq came to Turkey after Saddam Hussein's government brutally repressed those regions in the late 1980s. Currently, the temporary protection regime applies to all persons of Syrian nationality and persons of other nationalities who have come to Turkey to claim international protection as a result of events that occurred after April of 2011, that is, the Syrian civil war, and virtually all of the 3.7 million Syrians that you've seen in that first slide, the UNHCR table, are registered as persons under temporary protection. Now, all these status is grant certain rights and but some are only applicable to refugees because Turkey has an international obligation only for these people who fall under the definition of refugee people from Europe. The refugees, if you fall under a refugee category, then you have all the rights and privileges that come from the 1951 convention, and one in practice, very important right is access to employment once you receive refugee status, but all the other types of protection also share these core rights. The most important, of course, is the principle of non-refoulement, which means that the government cannot return you to a country where you will face prosecution or fear that you will face prosecution because of race, religion, nationality, membership of a particular social group or political opinion, or because you will face the death penalty, inhuman or degrading punishment or arbitrary violence. Also, application by itself means that you have leave to stay in the country and having made an application or having obtained the status will give conditional access to health and education services. Access to employment on an exceptional basis, we'll explain, you know, why it is exceptional later. But the government does not subsidize access to accommodation outside of camps that are built for Syrian refugees, people of -- so under temporary protection. However, a very small minority of Syrians are in camps now. A vast majority of them are in urban centers where they will have to pay for their own accommodation. The same goes for conditional refugees. So in this slide, I wanted to visualize the legal framework that governs the whole asylum system and also the experience of asylum seekers in in Turkey, so the main piece of legislation is the LFIP. On the basis of this legislation, there are some secondary legislation that governs the details. So the RFIP, the Regulation on Foreigners and International Protection, is the implementing regulation of the LFIP. It governs all the details, all the details of the processes that are provided under the LFIP. The regulation on temporary protection details the process of the grant -- the granting of the temporary protection status. The regulation on the work permits to be issued to foreigners under temporary protection is a regulation that details how work permits are going to be issued to Syrians under temporary protection. Now, there is another type of secondary legislation that is called in the literature untitled regulatory acts. These are typically called circulars, communiques, notices, guidelines, direct directives, or there's etc. You -- there's -- you know, you might come across these kinds of rules when you are doing research in the field. Now, these are typically issued for regulating the internal operation of the administration, but if they are used for regulating the rights and interests of members of the public, they must be published in the official journal. In practice, we see that sometimes they are published there, sometimes they are published in the websites of the of the, you know, relevant agency and sometimes they are not published. You will see in practice that certain administrative acts will be based on, you know, these untitled rules, and it might be the case that you won't be able to find them in public databases or the government's official websites. And if that is the case, your best, you know, the your best option is going to be to scour the internet and hope that some -- like an attorney who was part or took part in a in a lawsuit has uploaded this to the internet, and you can find it. There are some paid legal databases that compile these sort of rules, but they're always paywalled. So these rules can be issued under the LFIP, but also under the secondary legislation regulations. Of course, then we have the individual administrative acts that are issued on the basis of the law or the secondary legislation. In the Turkish administrative law system, every administrative act must have a basis in primary or secondary legislation, and legal action might be brought against an individual administrative act or the regulatory act, the secondary legislation. In practice of course, the asylum procedure involves many administrative acts. So under the Turkish constitution, any administrative acts are subject to judicial review. I also want to draw your attention to certain other legislation that are very relevant to the process and experience of asylum in Turkey. One of the important ones is the law on Turkish citizenship. Crucially, this law requires the person to be resident in Turkey for five years to obtain citizenship through naturalization. Also, it has a provision that provides that the time spent in the country as an asylum applicant or asylum status holder will not be counted towards the residency requirement, so persons who have the status or are applicants, if they want to obtain citizenship, they have to go through another route, for example marrying, you know, a Turkish citizen. Another important law is the law on international labor force. This governs the issuance of work permits to foreigners and migrants, and it has a provision that says international protection -- applicants can apply for work permits six months after their initial application for status. In practice, we see that work permits are issued on an exceptional basis and very rarely. Another important law is the law on administrative adjudicatory procedure which governs the process and administrative courts that will conduct the judicial review of administrative act. So this is a chart of the organization of the migration administration in Turkey. The whole operation is under the Ministry of Interior Affairs, and the international protection and temporary protection system is governed by the Presidency of Migration Management that is underneath the Ministry of Internal Affairs. This was previously known as the General Directorate of Migration Management. The presidency has a central organization, which is headquartered in Ankara, and a provincial organization which is -- which exists in 81 provinces of Turkey. Now, under the provinces, you will have the organization led by the governorships in the provinces. You'll come across in the literature, the mention of provincial directors of migration management, and district directors of migration management, but if you look at the legislation, usually applications and there are a lot of administrative steps that take place in the governorships. Now in the Turkish administrative system, these are the same. If you make an application to the Provincial Directorate of Migration Management, because this is organized under the governorship, you are making an application to the governorship. Just for reference, Turkey has 81 provinces. So these are the provinces, and to orient you, this is Turkey with its neighbors. So the provincial directorates of migration management and district directors of migration management are very important because in practice, many of the procedure takes place within the within these organizations. I've included a slide here that highlights some relevant important provisions of the LFIP, the main primary legislation, but I will not go over this. This is here for your reference. You will receive the slide set after the presentation. So, you know, it might help you navigate the LFIP when you're working with it. Okay, now, let's look at what the procedure is to apply and obtain the condition of refugee status in Turkey, and then we will look at the procedure for temporary protection now. I'm focusing on these two statuses, condition refugee and temporary protection, because as I might have said in the beginning, these represent the vast majority of asylum cases in Turkey. Conditional refugee is for anyone who is coming to claim international protection that is from a country that is not in Europe, and not Syrian, and the temporary protection is for Syrians who are coming to Turkey after the Syrian civil war. Now, a case we'll start with the crossing of the border, so an immediate question is whether the asylum seeker is going to be subject to deportation procedure, and therefore pre-deportation detention. There are various grounds for detention that might place an asylum seeker in this box. For example, lying when trying to enter is one. Trying to enter with false documents is another. Or a person could have been marked by the Turkish police before based on foreign intelligence or because, you know, previous events which took in inside of the country. In any case, if there's a ground for deportation, an asylum seeker might be placed into administrative detention under Article 53 of the LFIP, and the asylum seeker in theory may still apply for asylum while under the previous deportation administrative detention. Another possibility is that the asylum seeker enters regularly, so without, you know, satisfying any of the deportation reasons. Under the LFIP, the principle was that person should not be detained just because they are applying for international protection. However, under certain circumstances, for example, if the authorities need time to ascertain the identity or the country of origin of the applicants, the applicants might be placed under administrative detention, but this is a different type of administrative detention. We will go over this in detail later. So administrative detention can always be a challenge in courts, but not in administrative courts, but criminal courts. So if the asylum seeker is not detained and crosses the border or request international protection in the border, we are in the next stage, which is application. The application is made to the provincial or district Directorate of Migration Management. If the application is made while in detention, the police must forward the request to the Directorate, but there are reports that applications while in detention on the border are regularly not forwarded. So here we come across a central concept in the conditional refugee system, that is a satellite city or satellite province, depending on how you translate it, system. So under the conditional refugee system, conditional refugees and applicants for the conditional refugee status are required to reside in provinces to which they are assigned. These provinces are called satellite cities. Not all provinces are open to conditional refugees, not all provinces are satellite cities. Another feature is that the asylum seeker must make the first application for asylum, if they have crossed the border, in a satellite city. If they apply in a PDMM, a provincial directorate or a district directorate in a province that is not a satellite city or satellite province, in practice, they are referred to an open satellite province and they have to go there and apply there within 15 days. There is no assistance for travel though, so they have to go with their own means. So after a PDMM, a provincial directorate or a DDMM, a district directorate, receives the application, it will check whether the application is admissible. Grounds of admissibility include, you know, coming from a third country that is considered to be safe, for example. If the application is not inadmissible, then the applicant will be registered and required to reside in the province of registration. They will be required to apply for a permit, for example, to travel between provinces. They are only allowed to access services within that province in which they are registered. They are required to periodically report to authorities to prove that they have not left. Any violation of this residency requirement results in the withdrawal of the application. Inadmissibility decisions are open to judicial review. So as I said, registration comes with access to health and education services in the province of registration and movement restrictions. The free access to social insurance which enables access to health services is only valid for one year though, one year after application. After registration, within 30 days, an interview must take place, and after the interview, the presidency, the central agency, must come to a decision, a determination, a refugee status determination whether this person is going to be granted conditional refugee status or not. This must take within six months of the interview, but this period is not binding and in practice, there are reports of cases in which this took more than two years. The determination, the refugee status determination, is also subject to judicial review, administrative and judicial review. So what happens if you get the status? If there's a positive status determination, then the eventual objective is resettlement because this is a conditional refugee. This is done in cooperation with the UNHCR but it is rare, it is complicated. For example, last year, only around 12,000 resettlement cases were initiated and only around 7,500 were resettled. There are also other options. There is voluntary return and the law allows financial aid to be given to people who want to return voluntarily. This exists in every step of the process, but there are reports of abuse of voluntary return procedure. If the refugee status determination is negative, then the person will be invited to self-deport or if there is another deportation condition that exists then they might be placed under administrative detention and deported. The temporary protection procedure is, as you can see, a bit more straightforward, so. The reason is that there is no refugee status determination step, because the temporary protection status was designed for mass population movements and it was not feasible theoretically to provide for an individualized review and interview and refugee status determination step. So status is acquired by merely registering in a province. Significantly, very significantly, there is no satellite province or satellite city system in temporary protection. In principle, an applicant may apply for temporary protection in any province of her choosing. However, in practice, some provinces are closed. They do not accept applications, and significantly, Istanbul is one of these provinces. It is also another satellite city, so conditional refugees cannot be registered there also. This has very important implications, because temporary -- people under temporary protection or conditional refugees who are not registered in Istanbul cannot access any kind of health or education or employment in Istanbul if it is closed. So the temporary protection status also ends by voluntary return, the loss of temporary protection status due to certain factors that exist in the law, and the eventual end of the temporary protection regime which might be declared by the President of the Republic. As you might have noticed from our discussion of the procedure, for the condition refugee and temporary protection statuses, registration is determinative for access to basic services. Moreover, as I said, commercial centers such as Istanbul and Izmir are de facto closed for registration for either type of protection. So this unfortunately creates a dilemma for conditional refugees and people under temporary protection, so this -- that the registration system causes precarity is a theme that you will probably come across a lot in the literature on refugees and Turkey. The horns of the dilemma are staying put in this satellite city or the province of registration for temporary -- people under temporary protection, and moving to a large city. So staying put has its advantages, maybe most importantly, is that they are required by law to stay there, so staying is means regularity and not falling into irregularity. Also, access to education and health services are important. However, the disadvantages are, the economy is not doing very good and there are very little access to employment in small provinces, which are typically the satellite provinces. Now, moving to a large city might mean that there is employments opportunities, even though they are -- they will be in the informal economy, and also migrant networks, which is really important for the welfare of asylum seekers. Of course, the disadvantages are the loss of status, which is caused by living in a city that is, you know, outside of the of the town or province that you're registered in, and the cost of living, which is very high in large cities, especially in a slum. Let us look in a bit more detail to administrative detention. So we have come across administrative detention in previous slides. Here we are looking at the differences between pre-deportation detention and post-application detention which are two different things, regulated in two different articles of the LFIP. The first, pre-deportation detention is the most -- the more severe, and according to some observers, the more problematic. If a person satisfies deportation conditions, then this person might be put in administrative detention and the deportation decision must be made within 48 hours by the governor of the -- governorate of the place where the person was detained. The maximum period of detention is 12 months, so a person can be kept in detention on 12 months minus the 48 hours in detention after a deportation decision was made. So probably the most questionable aspect of this type of administrative detention is that by a recent amendment in the LFIP, the period for filing an appeal against deportation decision was lowered from 15 to 7 days. There are reports that the seven days are not enough for public interest lawyers who work on these cases to put together a case and file it with an administrative court, and filing an action will automatically suspend the deportation, so it is very important. Usually, people who are under administrative detention under Article 54 are held in rural centers and the lawyers have difficulty reaching these people and filing within seven days to stop the deportations. The other type of administrative detention is the post-application detention, which we've also seen in the previous slides. This is an exceptional type of detention and cannot exceed 30 days. Both types of detention -- so the detention decision, not the deportation decision -- can be reviewed by criminal justiceships of the peace, so these are two separate types of administrative decisions. Deportation and detention decisions are two separate types, so they go to different courts. The recent 2019 amendments to the LFIP also brought alternatives to administrative detention, that is pre-deportation detention, but there are reports that these are still not being applied. They're awaiting the implementing regulations to be issued. So because we have mentioned judicial review a lot, let us look at the administrative court structure in Turkey. I think familiarity with the administrative court system may come handy in your research. So the first level of the administrative court system are -- they are simply called administrative courts. These are the trial courts. In practice, they may hold hearings, but typically they conduct bench trials based on the administrative record. So very importantly, these decisions of the first instance administrative courts are not published, and they are typically not available even in commercial databases. Most of the cases will end here, either with a decision invalidating an administrative act, or by the dismissal of an invalidation action. There's this note here, decisions on deportation decisions are final. This isn't the law, but there is a conflicting provision in the law on administrative adjudication procedure, so certain second-instance courses are hearing administrative appeals from administrative courts on deportation issues. That is, at the moment, not clear. The second-instance course in the administrative court system are the regional administrative courts. These kinds of review administrative court decisions, de novo. Some of their decisions are published and are accessible from the websites of some courts or in commercial databases, but they will usually be in commercial databases. They are -- nearly all of them, virtually all of them are paywalled. The apex administrative court is the Council of States. The decisions of the Council of State Chambers and the General Assembly of the Chambers are technically not decisional law, or in other words, controlling authority in the sense we are familiar in the common law system, but they are very, very persuasive authority for lower courts and the sister chambers within the Council of States. They only review points of law. So an asylum seeker may also apply to the Constitutional Court for relief, claiming that the administration has violated a fundamental right. The asylum seeker must exhaust all the administrative court remedies in the ordinary court system before going to the Constitutional Court. The Constitutional Court may also issue an injunction to preserve the status quo. And finally, after all domestic remedies are exhausted, an application may be made to the European Court of Human Rights, of course. So let us go over certain recent events that I think have shaped the current landscape in Turkey. Now arguably, these events have impacted both the material conditions of asylum seekers and asylees in Turkey, and the public perception regarding the refugee crisis in the country. In 2016-17, there was a spike in the international protection applications from people coming from Iraq and Afghanistan. These people are subject to conditional refugee status as they're not coming from Europe, which is, you know, a more precarious position than Syrians under temporary protection because, as we have discussed, their access to health and education services are more limited and more connected to the satellite city. In 2018, media outlets reported that Syrians were no longer to be registered in Istanbul. Istanbul was closed for temporary protection registrations for Syrians under temporary protection. So because Istanbul was closed, it made worse this precarity-producing dilemma, because most of the jobs are located in Istanbul. Most of the education opportunities are located in Istanbul. Also in 2018, the provincial directorates of migration management, or rather the Presidency of Migration Management, the whole like the agency, took over all tasks related to the filing and registration of international protection applications from the UNHCR, which was doing the initial filing of the applications with its local implementing partner. Some reports suggest that the provincial directorates, which were supposed to -- which are at the moment are doing the application and registration processes, were not exactly ready to take over these beauties from the UNHCR, and that this led to some inconsistent standards between different PDMMs, the Provincial Directorates, and led to a drop and also led to a drop in the quality of statistics that were published. In 2019, we see an increased public backlash to asylum seekers from all backgrounds and all types of protection. This led to -- arguably, it led to a decision of the Istanbul Governate in July of 2019. The Governate warned that all foreigners under the various protection regimes who are not registered in Istanbul were to return to their provinces of registration and the Governate increased the enforcement measures, such as checkpoints, increased checkpoints and raids to ensure that these people left Istanbul. This probably resulted in increased deportations but also an increase in irregularity because people decided to stay in Istanbul. Of course, irregularity means the loss of legal access to all kinds of services and employment. Later in 2019, also there -- several amendments were made to the LFIP and most significantly, the period for, as we mentioned, the period for appealing a deportation decision was reduced from 15 to 7 days. And the social insurance allowance of conditional refugee applicants and status holders were limited to one year, limiting their access to free health care unless they find legal employment to pay their insurance premiums themselves after, you know, one year after their initial application. That is not the same for Syrians under temporary protection. So in 2020, there was this decision of the Turkish Government to not stop the movement of refugees to the Greek border. According to some reports, you know, the government also encouraged some people to move, controversial, which caused an international crisis with Greece. This is what the Edirne events are referring to. However, this crisis coincided with the beginning of the COVID-19 lockdowns. Of course, you know, the COVID lockdowns and the pushback from Greece and all the conditions of the people who were stuck in between Turkey and Greece created a nightmare scenario for these asylum seekers that were involved in the Edirne events. In 2021, the economic shock continued, with a majority of conditional refugees and persons under -- Syrians under temporary protection losing their livelihoods that they, you know, gained from informal and formal employments. COVID-related measures also impacted the procedural logistics of asylum as access to government services were strictly dependent on subscribing to digital COVID monitoring systems, which you couldn't do without regular status. People without ID numbers, for example, could not even enter public buildings to make an application, that is. In 2022, the Presidency of Migration Management introduced the practice of designating neighborhoods where more than 25% of the residents were foreigners, were closed. They are designated as closed neighborhoods, so no other foreigners under -- both under international protection but also regular migrants were not allowed to reside in neighborhoods where more than 25% of the population was foreigner. And recently, the limit was reduced to 20%, and as of the end of June, there were 1,169, closed neighborhoods. And finally, in 2023, there will be the national elections, and we'll see how the, you know, the increasing anti-refugee sentiment is going to play out. Political parties are responding to this and we will see. Okay, and we are already at 43 minutes, but very quickly, I want to go over certain tips for legal research and certain, you know, not very ideal practices that I came across when I was doing my research. Now so to access legislation -- very quickly, to access legislation and regulatory acts, the best -- if you don't have access to commercial databases, that is, the best publicly available platform is the government's own platform, mevzuat.gov.tr. So basically, it looks like this. You enter the name of the legislation you're looking or the number, for example, yeah, 6480. This is the LFIP's numbers, so you enter it and then you'll find the law. Just to point out to certain things in this is how the text of the law looks like, right? So you'll find the relevant information here. This is the number. There's the -- Resmi Gazete is the official gazette and the number and date is usually cited when -- in the full citation of Turkish law. One other thing that you might look at is, in practice, I've come across -- in the literature, I mean, not in practice -- I've come across certain references to out of date translations of Turkish laws. If you go to the bottom of laws that you pull up from mevzuat.gov.tr, that you will find this table which tells you the latest amendment to the law with the amending legislation here and the -- am I still -- ? Oh, [inaudible] fine. Okay, sorry about that. You can see the date of amendment and the articles that were amendment. So what you can do is if you come across a Turkish -- an English translation, for example, of a law, you should check the original law to see whether the translation you have found is up to date. If you don't see the, you know, the changes in these articles on this time, then you are working with an out of date law translation. One other interesting thing that you might not be familiar with is the Kaysis system, the Kaysis public administration database. It looks like this. Here, you can find the -- I like this because here you can see the whole administrative organization, the structure of the agencies, so Icisleri Bakanligi is the Ministry of Internal Affairs. If we go to the presidency, Goc Idaresi Baskanligi is the presidency of Migration Management, and you can see the entire administrative organization here. So for example, the -- let me see -- the International Protection General Directorate, here is the organization of that unit. This site also has a search function here to search for legislation, but different from mevzuat.gov.tr. It can also search for these untitled legislation. It is easier to find here. You can do it also there, but it's easier to do it here, so I searched for gecici koruma for example, which means temporary protection, and then I find for example, this -- let me see. Interesting. Okay, when I made a previous search, this document appeared. You won't be able to find this in mevzuat.gov. This is probably not even published, but it is about the procedure to be used by the administration in processing the marriage applications of migrants, so these documents are very important and have great impact on the experiences of asylum seekers, but they are not easily reachable. You should search for them on the Kaysis system to reach them. My last two minutes, I just want to go over one other, you know, not-ideal practice that I came across. Also in this slides, there are certain links to helpful resources from the Ankara Bar Association, an NGO, the Refugee Rights Turkey website, a legal information platform that they prepared for practitioners, and also Refugee Rights Turkey handbook for refugee law practitioners which is a compilation of relevant legislation and certain other documents. Yeah, I was mentioning about not-ideal practice which is concerning citation rules and conventions. I found that in English language literature, citations are not made properly to court decisions and legislation, so this slide shows you the is the best way to cite court decisions and legislation. An important point is when you are citing to a court decision, you should always include the name of the court, the date, the E and K numbers, so E stands for the docket number, and K is the decision number. In practice, these are always, always cited. If you only include one number, it is not easy to understand whether, you know, you're referring to the docket number, or the decision number, and they are, as you can see, in the same format, so always include the E and K numbers together. The same goes for high court decisions. Danistay is the Council of States, so it is cited in the same format. For the constitutional court decisions, in this area of the law, you will mostly, nearly always maybe, deal with individual applications with the constitutional courts, and these are cited by the name of the applicant. This is just a random case that I pulled up. The B. No. is the application No., and the date. For legislation, provide the law number and the last amendment so that your reader can understand which version of the law you are referring to, if you're referring to a law that, you know, a law as it existed in the past or not. Regulations do not have numbers, so for them, you have to provide the name and the official gazette information, date, and the number of the official gazette or official journal that it was published in. This brings us to the end of the presentation, so I'd love to answer the questions I will answer them [inaudible] the Q&A function. Oh, yeah. Someone -- yeah. Mr. [inaudible], I've mentioned that I said prosecution instead of persecution, which is completely correct. Yes, I meant -- yes, persecution. I think I mispronounced that word when I was discussing the definition of refugee, so just be aware that I meant of course, persecution and prosecution. Question, legal consequences of weaponization of refugees, and their use as a bargaining chip by the Turkish state in its negotiation with the European Union. Legal consequences, well, when we're talking about legal consequences, of course, we must think about the international law obligations of Turkey. Now I am not an expert in the area of like this particular area about like EU-Turkey relations, but depending on the legal significance of the EU-Turkey agreement about the, you know, the refugees that was done in 2016, Turkey might have certain international law obligations. That might be a source of legal consequence. Also, Turkey is part of the, you know, European Convention of Human Rights, and one might argue that, you know, this sorts of [inaudible] with like the sort of behavior by the government, arguably, maybe could give rise to certain violations of Turkey's human rights obligations under the European Convention of Human Rights if you can I make the case. So if you are looking -- if you're thinking about legal consequences, then it is international law that you have to find them. Emmanuel Gunrin [phonetic] has asked -- okay, from what I have been hearing, I would say that it is futile for anyone claiming refugee status in Turkey, as they have no chance of getting it. Consequently, it is logical to conclude that the regulatory framework on Turkey's on refugee close the door. Given this asterisk and not violated [inaudible] this convention on status of refugee Geneva convention. Yes, so it goes back to the geographical limitation that Turkey -- to the Geneva Convention of 1951. Because of the declaration, the explicit declaration that Turkey has, that Turkey has an international obligation under the Geneva Convention of 1951 only for people who are coming from, you know, because of events occurring in Europe. So under international law, Turkey does not have an international obligation, at least under the convention to provide refuge to people coming from other places. Of course, there's the discussion of whether, you know, offering asylum is a customary international law has become a customary international law rule. At least, there's a very powerful argument that the principle of non-refoulement is an international norm, customary international norm now, but the geographical limitation does, to a great extent, limits Turkey's international obligation. [inaudible], can you compare and comment on refugee rights and protections in Turkey to the rest of Europe or its immediate neighborhood? Well, I, of course have concentrated my research on Turkish international production law, but we know for a fact that the LFIP was largely inspired by the EU qualification directive, which is the piece of legislation that harmonizes the definitions of refugee and international protection in the European Union, so in the rest of Europe, at least in European Union member states, the EU qualification directive is going to be the main document to compare this system, but I cannot do it now, unfortunately, of course, because I'm not an expert in European Union countries or the laws of those countries, but that is the exercise that must be done. Also, of course, that is only a directive, so it is not directly applicable, and they have to be transposed into municipal domestic law in European Union states and probably they have different ways of doing it. So at the European level, you will have the directive but also a comparison must be done between the domestic laws of European Union, European Union member states and the Turkish system. Is there any English sites to search legislation on case law? I don't know if there is any good one. There are certain sites that use machine translation. There is of course, the UN's websites, especially worldref, refworld. [inaudible] mix these up. The -- so let me see if -- refworld, this website where you can search for a case law -- or not case law, national legislation. And if we go to Turkey, there are many translations of Turkish laws, but sometimes the translations will be out of date. That is why I want to like stress this point. You have to check, go to this table underneath the originals of the laws in mevzuat.gov and then see whether the law was amended, and then compare that with the translation you pull from refworld for example. I don't know if there are paid services, commercial services, though. There might be, but I'm not using them. Yeah, we are -- it is 3 p.m., and I have no more open questions, so thank you so much for coming to listen to this webinar. I hope it was useful, and please -- compared to the webinar, which is going to be the laws of Mexico and how to find them online on September 22nd at 2 p.m. All right. Thank you very much.