CAT/C/63/D/719/2015 consideration of whether a medical report should have been submitted in the first asylum application and that they are, therefore, an effective remedy. 4.3 The State party disputes the complainants’ statement that an appeal would not be an effective remedy as it has no automatic, suspensive effect and allows the Government of the Netherlands to initiate the complainants’ expulsion. The State party maintains that the complainants had the opportunity to apply to the Division for an injunction to prevent their expulsion pending appeal. Pursuant to sections 8:81 and 8:83 (4) of the General Administrative Law Act, a judge responsible for provisional measures in appeal proceedings must assess the risk of a violation of article 3 of the Convention upon the asylum seeker’s return to his or her country of origin and must deliver his or her judgment before expulsion. Therefore, the complainants’ conclusion that the higher appeal did not have to be exhausted is not warranted. Complainant’s comments on the State party’s observations 5.1 On 26 February 2016, the complainants submitted their comments on the State party’s observations. The complainants maintain that their application for asylum is plausible given article 3 of the Convention, arguing that the Committee’s jurisprudence requires a flexible approach to plausibility standards in order for the article to be applied effectively.12 5.2 The complainants contest the State party’s argument that domestic remedies provide an opportunity for suspension of their expulsion. They state that neither the lodging of an appeal, nor of an injunction pending the appeal, have automatic suspensive effect. They refer to the European Court of Human Right’s decision that the possibility of requesting a suspension of an impugned measure through an urgent procedure is not a sufficient remedy unless it allows for the rigorous scrutiny of the merits of the claim. 13 Rather, this remedy allows for possible expulsion without complete scrutiny of the claim, violating article 3 of the Convention. 5.3 The complainants also refute the State party’s argument that the scope of a higher appeal to the Administrative Jurisdiction Division would not be limited to the procedural question of whether a medical report submitted after the initial asylum application can be substantively considered as a new fact. They refer to two expert opinions stating that the Division requires a “legally justified reason” for the late submission of a medical report. Without the “legally justified reason,” the appeal would be strictly limited to the question of whether new facts have been presented, with no substantive assessment of the merits of the case. As to the three decisions referred to by the State party, they point out that, in its decisions of 14 January 2011 and 28 June 2012, the Division ruled that the applicant had failed to provide a legally justified reason why he did not initially request a medical report. Thus, these cases support their allegations that a further appeal would be limited to the question of whether the medical report constituted a new fact. Furthermore, the decision of 28 December 2015 held that the medical report was insufficiently taken into account in reviewing the article 3 violation in the light of new facts presented by the complainant regarding a deteriorating situation. By itself, the medical report did not constitute a new fact that allowed for substantive investigation. The complainants conclude that the State party’s provision of only three cases out of Division case law stretching back over more than 15 years, none of which demonstrate that the appeal will focus on more than the validity of the Netherlands Institute for Human Rights and Medical Research report as a new fact, suggest that a further appeal has virtually no prospect of success in determining the merits of their application. State party’s observations on the merits 6.1 In its submission dated 9 June 2016, the State party provided information on the merits of the case. After briefly restating the facts of the case, the State party elaborated on 12 13 4 See, e.g., Mutombo v. Switzerland (CAT/C/12/D/13/1993), para. 9.2. See European Court of Human Rights, M.S.S. v. Belgium and Greece (application no. 30696/09), judgment of 21 January 2011, paras. 387–390.

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