greater funding opportunities for resettlement. Since 2010, four EU countries have started to establish resettlement programmes - Bulgaria, Germany, Hungary and Spain. 24. UNHCR. Asylum Trends 2012: Levels and Trends in Industrialized Countries. March 2013. p.7. This compares to the 19% increase that Europe experienced in 2010/2011 (reference: UNHCR. Asylum Levels and Trends in Industrialized Countries. 2011. p.7). 25. 31. In November 2007 the European Commission presented an Evaluation Report on the Reception Conditions Directive in which it concluded that poor implementation of the provisions meant that asylum-seekers were not provided with an adequate standard of living in many EU Member States. Asylum-seekers also faced significant legal and practical obstacles to access employment, education and health care. 32. M.S.S. v. Belgium and Greece (Application no. 30696/09), judgment of 21 January 2011. The court found that Greece was in violation of Article 3 ECHR due to the inhuman and degrading detention and living conditions that an asylum applicant had been placed in whilst awaiting his asylum determination in Greece. In addition, the court considered that by transferring the applicant to Greece, under the Dublin II Regulation, the Belgian authorities knowingly exposed him to conditions of detention and living conditions that amounted to degrading treatment, and therefore Belgium was also found to have violated Article 3 ECHR. 33. UNHCR. Asylum Trends 2012: Levels and Trends in Industrialized Countries. March 2013. p.8. Ibid. p.7. The 15 pre-2004 (‘old’) EU Member States accounted for 93% of all asylum claims in the EU. 26. Ibid. The Nordic countries comprise: Denmark, Finland, Iceland, Norway and Sweden. Sweden received 70% of all asylum claims in the Nordic region. 27. quickly and efficiently as possible. The amendments to the Dublin II Regulation were negotiated as part of the second phase of the CEAS and were formally adopted in the Dublin III Regulation in July 2013. Ibid. p.8. Southern European countries comprise: Albania, Cyprus, Greece, Italy, Malta, Portugal, Spain and Turkey. The drop is due to a fewer number of boat arrivals in Italy than occurred in 2011. In contrast, Turkey continued to see an increase (+8%) in new asylum claims for the third consecutive year (this figure excludes Syrians registered in refugee camps). 28. The Common European Asylum System (CEAS) was created to address the disparities in asylum systems and practices among EU Member States through the harmonisation of asylum systems within the EU. The first phase of the CEAS, completed in 2006 under the Hague Programme (2004-2009), included three directives and one regulation. These instruments were reviewed as part of the current second phase of the CEAS (2010-2014). The European Commission proposed improvements and modifications in four “recast proposals”, which were negotiated with the European Parliament and European Council (made up of relevant ministers from all EU Member States). The amendments were formally adopted in June 2013. 29. Council Directive 2003/9/EC of 27 January 2003 laying down minimum standards for the reception of asylum seekers (Reception Conditions Directive). OJ L 31/18; Council Directive 2004/83/EC of 29 April 2004 on minimum standards for the qualification and status of third country nationals or stateless persons as refugees or as persons who otherwise need international protection and the content of the protection granted (Qualification Directive), [2004] OJ L 304/12; Council Directive 2005/85/EC of 1 December 2005 on minimum standards on procedures in Member States for granting and withdrawing refugee status (Asylum Procedures Directive). OJ L 326/13. 30. Commission Regulation (EC) No 1560/2003 of 2 September 2003 laying down detailed rules for the application of Council Regulation (EC) No 343/2003 establishing the criteria and mechanisms for determining the Member State responsible for examining an asylum application lodged in one of the Member States by a third-country national. OJ L 222/3 (“Dublin II Regulation”). The Regulation outlines the arrangements under which an asylum applicant may be returned to another EU Member State and aims to prevent the secondary movement of asylum-seekers within the EU, whilst ensuring they have effective access to procedures for determining refugee status as 82 / Recognising victims of torture in national asylum procedures 34. UNHCR Resettlement Handbook, Country Chapters – Canada, July 2011, section 8.2. 35. Canada. Immigration and Refugee Board of Canada. Guideline on Procedures with Respect to Vulnerable Persons Appearing Before the IRB. Paragraph 1.5. 36. Amnesty International. Annual Report 2012 on Canada. Available at: http://www.amnesty.org/ en/region/canada/report-2012#section-24-5 (accessed on 14 May 2013). 37. Meffert S., Musalo K., McNiel D. and Binder R. The Role of Mental Health Professionals in Political Asylum Processing. Journal of American Psychiatry Law. 2010; 38: 479-89. 38. Physicians for Human Rights. Factsheet on One-Year Bar to Asylum. Available at: https:// s3.amazonaws.com/PHR_other/factsheets/OneYear-Bar.pdf (last accessed on 23 September 2013). The one-year deadline will only be waived on the basis of changed or extraordinary circumstances, but it is often difficult to satisfy asylum officers, immigration judges and board of immigration appeals (BIA) personnel reviewing asylum claims filed after one year that an application meets one of these broad exceptions. 39. Physicians for Human Rights. Factsheet on Asylum and Other Relief for Immigrant Victims of Violence and Persecution. Available at: https:// s3.amazonaws.com/PHR_other/factsheets/ asylum-and-other-relief.pdf (last accessed on 23 September 2013). Note, however, that the Supreme Court has only accepted review of a handful of asylum cases since the Refugee Act was authorised in 1980. 40. Ramji-Nogales J. et al. Refugee Roulette: Disparities in Asylum Adjudication. Stanford Law Review. 2007; 60(2): 309. For an overview of the US