Is N.D. and N.T. v. Spain the new Hirsi?

Annick Pijnenburg

Research output: Memorandum/expositionCase noteProfessional


On 3 October the Third Chamber of the European Court of Human Rights published its judgment N.D. and N.T. v. Spain, which concerns Spain’s pushback policy in Melilla. It found a violation of Article 4 of Protocol 4 (prohibition of collective expulsions of aliens) and of Article 13 (right to an effective remedy) taken together with Article 4 of Protocol 4. This post focuses on the issues of jurisdiction and the prohibition of collective expulsions addressed in the judgment, as well as its policy implications.
Original languageEnglish
Project No.8675/15 and 8697/15)
File no.ECtHR
Publication statusPublished - 17 Oct 2017

Publication series

NameEJIL Talk!


  • ECtHR
  • Refoulement
  • Spanish enclaves
  • jurisdiction


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