ties and a person’s duration of residence in a country) that have led the HRC to apply Art. 12(4) to individuals in subsequent decisions (see Nystorm v Australia and Warsame v Canada). Other interpretations of Art. 12(4) also point to the importance of a country facilitating the re-entry of its citizens who have travelled abroad – specific concerns have been raised, for
instance, in the context of the
Syrian Government’s failure to issue passports to some
Syrian citizens abroad, effectively barring them from re-entering
Syria (see Concluding Observations of the...