68 OTHMAN (ABU QATADA) v. THE UNITED KINGDOM JUDGMENT establish the effectiveness of the assurances given by Jordan, to rely upon material which was not disclosed to him. Article 13 provides as follows: “Everyone whose rights and freedoms as set forth in [the] Convention are violated shall have an effective remedy before a national authority notwithstanding that the violation has been committed by persons acting in an official capacity.” A. The parties’ submissions 1. Government 209. The Government adopted the reasoning of the House of Lords in the present case (see paragraphs 54–56 above). They submitted that the Court’s established case-law made clear that an effective remedy under Article 13 was not required to satisfy all the requirement of Article 6. All that was required by Article 13 was independent and impartial scrutiny of an applicant’s Article 3 claim. This in turn required that an independent appeal body be informed of the reasons for deportation; there had to be a form of adversarial proceedings, if necessary through a special representative with security clearance; and that the body be competent to reject the executive’s assertions where it finds them arbitrary or unreasonable (Al-Nashif v. Bulgaria, no. 50963/99, §§ 133–137, 20 June 2002; C.G. and Others v. Bulgaria, no. 1365/07, §§ 57 and 62, 24 April 2008). 210. SIAC procedures clearly satisfied these requirements. As the Court had held in A and Others v. the United Kingdom, cited above, § 219, it was a fully independent court, which could examine all the relevant evidence, both closed and open. This is especially so, given the Secretary of State’s obligation to disclose evidence which helps an appellant and the fact that the closed sessions enabled SIAC to see more evidence than would otherwise be the case. Proceedings before SIAC were adversarial, involving the applicant’s own representatives and, in closed sessions, the special advocates. SIAC’s jurisdiction was not limited to reviewing the executive’s decision on grounds of arbitrariness or unreasonableness: it conducted a full merits review and had allowed appeals against deportation, for instance in DD and AS (see paragraph 74 above). In the applicant’s case, SIAC had stated in its open judgment that the closed evidence played a limited and confirmatory role in its decision. 2. The applicant 211. The applicant observed that, after Chahal, cited above, SIAC and the system of special advocates had been designed to allow the Secretary of State to present her case as to why a particular returnee was a risk to national security, not to allow secret evidence on safety on return. A ministerial assurance to that effect had been given to Parliament when it