The Court’s response is described and analysed extensively, demonstrating its insistence on fundamental protection principles. The article depicts these efforts and the intertwined usage of law and policy measures by various actors in the European arena. Following the terrorist attacks on 11 September 2001 a variety of attempts were made to have the European Court of Human Rights modify its interpretation of Article 3 as providing absolute protection against refoulement. The legal developments pertaining to the non-refoulement principle under Article 3 of the European Convention on Human Rights provide ample illustration of the dilemmatic relationship between refugee protection and anti- or counter-terrorism measures.
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