Case Law Database

Smuggling of migrants

Offences

• Enabling illegal stay
• Financial or other material benefit (to smuggler)

Mode

• land

Areios Pagos 1874/2002

Fact Summary

Date(s) of offending: on/from 12 May 2001 to 12 May 2001

On May 12th, 2001, the appellant, along with his accomplice and relative of the smuggled migrants, with intent to obtain illegal profit, transported foreign nationals within Greece. In particular, he collected with his taxi two Georgian nationals, who have entered into Greece illegally crossing the Greek-Bulgarian border two days before, on May 10th, 2001, from the village Ifestos near Komotini, in order to transport them to Athens. The appellant would receive 300,000 drachmas for this transport.

Commentary and Significant Features

1. Mens rea and evidence

 

Areios Pagos that the mens rea includes knowledge of the illegal entry of the smuggled migrant, which should be referred to in the judgment in order for it to have the reasoning required by law.

It further concluded that the Appeals Court correctly established that the appellant knew that the persons he transferred had entered illegally, based on the following: 1. the fact that he agreed to transfer them with his taxi setting a rate at double the regular rate for this trip, thus assuming the relevant risk and 2. on the return trip from Komotini to Athens he chose a different route in order to avoid a border police control point that he had identified when he went from Athens to Komotini.

 

2. Law to be applied

 

Areios Pagos upheld the Appeals judgment that Law 1975/1991 (applicable at the time of the offense) should be applied instead of Law 2910/2001 (applicable at the time of the judgment), as more favourable for the defendant, since the penalty range provided under Law 1975/1991 was lower.

 

3. The ex post facto possibility of obtaining residence permit on behalf of the smuggled migrants does not render the act not criminal

 

The appellant claimed that taking into account article 66 of Law 2910/2001, which entered into force after the commission of the crime and provided for the possibility for “illegal aliens” to file an application to be granted residence permit, under certain criteria, the two foreign nationals that he transported should not be deemed as “illegal” since the two-month deadline to file their applications under the aforementioned article had not yet expired. The Court found that the ex post facto possibility of obtaining residence permit on behalf of the smuggled migrants does not render the act not criminal, and that in any event, the individuals concerned did not meet the requisite criteria in order to obtain permits.

 

4. Confiscation – constitutionally protected right to ownership – suspension as adjunctive penalty

 

Areios Pagos dismissed the appellant’s argument that the confiscation of his taxi violates the right to ownership. In particular, Areios Pagos found that the right to ownership is weakened in such cases, due to the abuse of the right when the owner uses their property in order to commit a crime. Consequently, the owner exercises their ownership rights at the expense of the common good, and therefore confiscating this property does not violate the constitutionally protected right to ownership.

Furthermore, the appellant complained that since his main imprisonment sentence was suspended, adjunctive penalties such as confiscation should be suspended too and his taxi returned to him. Areios Pagos found that only certain adjunctive sentences are to be suspended, such as deprivation of rights (e.g. to right to vote and to hold public office), which do not include confiscation, which remains in force. However, there was a dissenting opinion by two members of Areios Pagos, meaning that the final decision was reached by a majority of one vote, and thus the matter was referred with regard to this issue to the Plenary Session of Areios Pagos.

Cross-Cutting Issues

Liability

... for

• completed offence

... based on

• criminal intention

... as involves

• principal offender(s)

Investigation Procedure

Involved Agencies

• Border Police

Confiscation and Seizure

Seized Property

Property sized: Car (taxi)

Legal basis of confiscation: Art. 33 par. 1 Law 1975/1991

Since his main sentence was suspended, the appellant argued that the adjunctive penalty of confiscation of his vehicle should be suspended too. Areios Pagos dismissed this plea by a thin majority, which led it to refer the matter to the Plenary Session of Areios Pagos.

 

Procedural Information

Legal System:
Civil Law
Accused were tried:
together (single trial)
 
 
Proceeding #1:
  • Stage:
    Other
  • Details:
    (Appeal before Areios Pagos – “Anairessi”)
  • Official Case Reference:
    Areios Pagos 1874/2002
  • Decision Date:
    Tue Oct 08 00:00:00 CEST 2002

    Court

    Court Title

    Areios Pagos (Άρειος Πάγος)
     

    Location

  • City/Town:
    Athens
  • • Criminal

    Description

    The appellant was found guilty by virtue of judgment no. 802/2001 by the three-member Court of Appeals of Thrace. He lodged an appeal to Areios Pagos on August 16th, 2001. Areios Pagos upheld the Court of Appeals judgment, but referred the matter to the Plenary Session on the issue of suspension of the confiscation due to the relevant thin majority.
     

    Outcome

  • Verdict:
    Other
  • Other Outcome

    Upheld.
     

    Migrants

    Migrant:
    2 persons
    Gender:
    Female
    Nationality:
    Georgian

    Defendants / Respondents in the first instance

    Number of other accused:
    1
    Defendant:
    Unknown
    Gender:
    Male
    Nationality:
    Greek
    Appellant in this case before the Supreme Court (Areios Pagos). Since his sentence was suspended, it is safe to conclude that he did not have a record of prior (serious) offending. Resident of Aigaleo in Athens.

    Charges / Claims / Decisions

    Defendant:
    Unknown
    Charge:
    Facilitation of transport within Greece
    Statute:
    1975/199133 §1
    Term of Imprisonment:
    Term of imprisonment unknown.