Migrants? death, dignity and European democracy, by Catherine Dupré

miladyrenoirmiladyrenoir
2024-10-30 11:31

Posted by ccld201

29 October 2024

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On 1 October 2024, eighty-eight membershttps://pace.coe.int/en/votes/39966

of the Parliamentary Assembly of the Council of Europe (PACE) adopted

Resolution 2569https://pace.coe.int/en/files/33815/html based on a report

on ?Missing migrants, refugees and asylum seekers ? A call to clarify their

fate?https://pace.coe.int/en/files/33711/html (Document 16037) prepared

by Mr Julian Pahlkehttps://julianpahlke.de/. Twenty-nine voted against

and four abstainedhttps://pace.coe.int/en/votes/39966. In its plenary

formation, PACEhttps://pace.coe.int/en/ encompasses 306 members appointed

by national parliaments from among their members across the 46 member

states of the Council of Europe. Eighty-eight votes in favour of

?consider[ing] that human dignity should be ensured to all persons in life

and in death, and that the obligation in law to treat the deceased with

dignity should extend to situations where international humanitarian law is

not applicable? (point 4) is a sobering figure.

Dignity, humanity, democracy

Yet, at the end of a summer marked by elections that saw the systematic

rise of anti-immigration, racist and xenophobic agenda across Europe,

including in the European Union (EU),<

https://results.elections.europa.eu/en/> France<

https://www.lemonde.fr/en/les-decodeurs/article/2024/07/07/2024-french-election-results-chart-and-map-of-second-round-winners_6676976_8.html>,

Germany<

https://www.theguardian.com/world/2024/sep/22/social-democrats-afd-alternative-germany-state-election-brandenburg>

and recently Austria<

https://www.theguardian.com/world/2024/sep/29/far-right-freedom-party-winning-austrian-election-first-results-show>,

this small figure encapsulates the hope that Europe?s democracy might not

be reduced to its electoral dimension alone. Democracy is not just about

free and fair elections. Human rights law developed by the EU, by the

Council of Europe and by their common member states is very clear that in

European democracy everyone matters, and that everyone matters equally.

Some people living in a democracy have the right to vote and to stand in

elections (mostly nationals of these states), and others do not. All

people, however, enjoy the same civil and political rights under the

European Convention on Human Rights<

https://www.echr.coe.int/documents/d/echr/convention_eng> (ECHR) that are

so crucial for democracy, such as the right to freedom of expression

(Article 10), freedom of assembly (Article 11) and fair trial (Article 6).

Moreover, the rights that protect people against being dehumanised are

absolute both under the ECHR and EU Charter of Fundamental Rights<

https://www.europarl.europa.eu/charter/pdf/text_en.pdf>. In the Council of

Europe, it is prohibited to subject people to inhuman and degrading

treatment or punishment, to torture, to servitude, to slavery, and to human

trafficking. In addition in the EU, the death penalty is abolished; eugenic

practices and reproductive human cloning are also prohibited. Those

eighty-eight votes reminding us that ?human dignity should be ensured to

all persons in life and in death?, also remind us that ? regardless of the

lawfulness of their status, entry or stay in the territories of the Council

of Europe and of the EU ? migrants, refugees, and asylum seekers share the

same humanity as everyone else living in the Council of Europe.

Dead and missing migrants matter

Crucial in life, this shared humanity is perhaps even more important in

death and when migrants go missing<

https://dtm.iom.int/europe/dead-and-missing>. In my contribution to the

preparation of the report<

https://rm.coe.int/asmiginf-2024-15-contribution-reflecting-on-the-dignity-of-the-decease/1680b1a054>

last spring, I elaborated on the significance of human dignity in the

following terms: ?The concept of human dignity primarily stems from Art.1

UDHR (1948), which states: ?all human beings are born free and equal in

dignity and in rights?. It is part of customary international law (ius

cogens) as embedded in the prohibition of torture and of inhuman and

degrading treatment[1]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn1>.

In European law, human dignity has become the foundation of human rights

and democracy[2]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn2>.

It is the EU?s first foundational value (Article 2 TEU), and the core

dignity rights are enshrined in the EU Charter (Art. 1-5). While the ECHR

did not codify human dignity, the ECtHR has made explicit that its

commitment to protecting ?human dignity and human freedom? is a question of

?civilisation? and ?the very essence of the Convention?[3]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn3>.

Human dignity is firmly embedded in its caselaw under Art.3 (prohibition of

torture, inhuman and degrading treatment and punishment) and Art. 4

(prohibition of forced and compulsory labour and of servitude and slavery).

[115.] Human dignity has become law?s tool to capture and protect what it

means to be a human being in a democracy. It has three important features:

it is inherent (it is enough to be born); it is universal and equally

shared by all human beings; and it enjoys the strongest protection

(?inviolable? under Art.1 EU Charter, and absolute and non-derogable in

ECHR caselaw). Consequently, human dignity arguments are especially

effective for protecting people at the margins of society and law; people

who are often not popular in the current political context and who tend to

be invisible and voiceless[4]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn4>.

It is particularly suited to promoting the rights of migrants, refugees and

asylum seekers[5]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn5

.

[116]. While human rights law has been developed for the living, treaty law

does not restrict dignity to them[6]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn6>.

How and why people die goes to the heart of humanity[7]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn7>.

As a result of systemic failures in relation to, or breaches of, absolute

prohibitions, (missing) migrants, refugees and asylum-seekers often die

inhuman deaths. Human rights law cannot give them their lives back. It can

however seek to give them their humanity back postmortem. For instance, and

pending further elaboration, when anchored in human dignity the duty (e.g.)

to locate their remains and identify them becomes universal in principle.

Further, this duty might be formulated in strong terms reflecting human

dignity?s outstanding status in human rights law. Finally, relying on human

dignity means that actioning the rights of the dead might no longer be

restricted to ?their relatives?. This might become an objective right on

the wider ground of humanity, as what is at stake is the right of all human

beings to belong to the ?human family? (UDHR) and, when dead, to have their

existence formally acknowledged and remembered.

[117]. Ultimately, the argument of human dignity is a powerful reminder

that, regardless of borders, we all share the same humanity. Beyond

promoting accountability, exploring the actual and potential routes offered

by human dignity also encourages timely reflection on the quality of the

?human family?, ?civilisation? and democracy[8]<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/#_ftn8>

that we live in.?

On the basis of the above Resolution 2569, the Parliamentary Assembly

adopted Recommendation 2284 (2024)https://pace.coe.int/en/files/33816/html.

It is addressed it to the Committee of Ministers, which is expected to

respond to the Parliamentary Assembly within a year. In the meantime in the

EU, following the electoral success of far-right parties over the summer,

creating offshore detention centres for migrants and ?outsourcing? checks<

https://www.theguardian.com/commentisfree/2024/oct/14/the-guardian-view-on-eu-asylum-policy-orban-is-no-longer-an-outlier>

is rapidly gaining traction amongst Member States. Italy?s recent decision<

https://www.theguardian.com/world/2024/oct/21/meloni-rushes-to-pass-new-law-to-save-albania-migration-transfer-policy-italy>

to ignore both the 18th October 2024 decree of the Tribunale Ordinario in

Rome<

https://effimera.org/wp-content/uploads/2024/10/DECRETO-Tribunale-di-Roma_18-ottobre-2024.pdf>

and the recent Court of Justice Preliminary Ruling (case C-40622 of 4th

October 2024 only available in Czech and French<

https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A62022CN0406>)

seems to confirm increasing contempt for the rule of law in general, and

for the rights of migrants in particular. It is important to bear in mind

that human dignity does not depend on where people die, it comes with

simply being born, no matter where in the world.

Catherine Dupre is a professor of comparative constitutional law and the

founding editor of the Dignity&democracy Blog.

Migrants? death, dignity and European democracy, by Catherine Dupré >

Dignity & Democracy<

https://sites.exeter.ac.uk/humanrightsanddemocracyforumblog/2024/10/29/migrants-death-dignity-and-european-democracy-by-catherine-dupre/

Marie Martin [she/elle]

Committee on Migration, Refugees and Displaced Persons

Commission des migrations, des réfugiés & des personnes déplacées

Office : +33 3 90 21 59 66 | Mobile: +33 749 794 763 (Signal/WhatsApp)

Council of Europe / Conseil de l’Europe

https://www.coe.inthttps://www.coe.int/

https://twitter.com/PACE_Migrationhttps://twitter.com/PACE_Migration/

email : marie.martin@coe.intmarie.martin@coe.int

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