foreigner must be given the opportunity to present the reasons that plead against his expulsion; b) to request the examination of his situation; c) to request to be represented before the authorities. The ECtHR has also established that Article 8 (right to respect for private and family life) contains procedural guarantees to prevent arbitrary interference with the right to privacy and family life. This can be important for people who have been in a state for a long time and who may have developed a private and family life there or who may be involved in court proceedings in that state. Deficiencies in the procedural aspects of decision-making within the meaning of Article 8 may lead to an infringement of Article 8 (2) on the grounds that the decision did not comply with the law. Article 13 of the International Covenant on Civil and Political Rights provides that “an alien lawfully in the territory of a State Party to the present Covenant may be expelled therefrom only in pursuance of a decision reached in accordance with law and shall, except where compelling reasons of national security otherwise require, be allowed to submit the reasons against his expulsion and to have his case reviewed by, and be represented for the purpose before, the competent authority or a person or persons especially designated by the competent authority”. The UN Human Rights Committee reiterated in one of its general comments (General Comment 15/27 of 22 July 1986, paragraph 10) that "Article 13 directly governs only the procedure and not the substantive grounds for expulsion". The Committee also recalls that the person who is the subject of an expulsion order should have access to legal representation in order to be able to present reasons for his expulsion (Concluding Observations on Denmark, 31 October 2001, paragraph 17). The ECtHR has emphasized that when the human right in question is an absolute right (prohibition of torture or the right to life), non-return becomes an absolute right and cannot be the subject of any exception, either in law or in practice. This practice applies regardless of national security considerations, other public interests, economic pressures or large flows of migrants. 65

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