In Amie and Others v Bulgaria,157 the Strasbourg Court considered an application submitted by a family of refugees (four of whom were stateless; one of whom had acquired Bulgarian nationality at birth) against a deportation order to Lebanon on ground of national security. When considering whether the first applicant’s detention, with a view to deportation, had been ‘lawful’ pursuant to Article 5(1) ECHR, the Court made the following statement with regard to the right to return and the lack of travel documents: 77. It appears that the only steps taken by the authorities during that time were to write four times to the Lebanese Embassy in Sofia, asking it to issue a travel document for the applicant. It is true that the Bulgarian authorities could not compel the issuing of such a document. However, there is no indication that they pursued the matter vigorously or endeavoured entering into negotiations with the Lebanese authorities with a view to expediting its delivery […]. Moreover, the Government have not provided evidence of efforts being made to secure the first applicant’s admission to a third country. Although the authorities apparently asked him to specify such a country, there is no indication that they took any steps to themselves explore that option. The Court is aware that, as noted by the United Nations High Commissioner for Refugees, the enforcement of expulsion measures against refugees – the Court would add, especially ones who are stateless – may involve considerable difficulty and even prove impossible because there is no readily available country to which they may be removed. However, if the authorities are – as they surely must have been in the present case – aware of those difficulties, they should consider whether removal is a realistic prospect, and accordingly whether detention with a view to removal is from the outset, or continues to be, justified. It follows that the 47 Contracting Parties to the ECHR have a positive obligation to secure an applicant’s admission and entry into a third country, prior to deportation. This is even more so where the applicant is stateless. In such cases, the deporting State must do all they can to ensure the issuance and delivery of a travel document to the applicant by the former country of residence or country of birth. One can infer from this judgment that should removal not be possible practically (because of lack of travel documents), the deporting State should lawfully admit the applicant into its territory,158 and facilitate naturalization.159 This position may be contrasted with that of US courts. Thus, the US Supreme Court does not normally require a target country’s permission before it is designated as a country for removal. 160 Amie and Others v Bulgaria, Application no. 58149/08, European Court of Human Rights, judgment of 12 February 2013, 4th Section. 158 This case builds on Amuur v. France, Application No. 19776/92, judgment of 25 June 1996, and Saadi v. UK, Application No.13229/03, judgment of the Grand Chamber of 29 January 2008. In an EU context, see also Article 15 of the Directive 2008/115/EC of 16 December 2008 on common standards and procedures in member states for returning illegally staying third-country nationals, limiting the maximum period of detention for removal purposes to six-months. Case C-357/09, Saïd Shamilovich Kadzoev v. Direktsia ‘Migratsia’ pri Ministerstvo na vatreshnite raboti, ECJ, 30 November 2009. 159 As recommended by the UNHCR, Handbook on Protection of Stateless Persons, para.168. 160 Jama v. Immigration & Customs Enforcement, 543 U.S. (2005) 335. According to US law, aliens ordered to be removed on criminal grounds (including stateless persons) should be removed to the country of their choice, or 157 28