These provisions have been applied in a number of appeals against the refusal to provide support to stateless and “unreturnable” persons.302 These cases do not indicate any link between statelessness, the lack of a prospect of removal, and eligibility for asylum support. Stateless and “unreturnable” asylum-seekers are often asked to apply for voluntary assisted return. There is, however, one particularly relevant decision which holds that a person who has applied for leave to enter or remain on the basis that they are stateless should be granted section 4 support because the failure to do so would leave him destitute, in breach of Article 3 ECHR.303 A number of conclusions can be drawn about support for refused asylum-seekers. First of all, the criteria for granting section 4 support were not drafted with the situation of stateless refused asylum-seekers in mind, who will often be unable to secure travel documentation or admittance to any country of former habitual residence. Requiring stateless persons to register for voluntary return when such return is, in the individual case, objectively impossible appears unduly onerous, and risks infringing human rights norms if applied too strictly. Secondly, although the Tribunal has recognised that statelessness can be a “juridically relevant fact”304 when assessing whether a failed asylum seeker should be entitled to support, it has done so on the basis of further submissions requesting leave to remain on the basis of statelessness. Other powers to provide support and accommodation The Secretary of State also has the power to provide accommodation to those on temporary admission, those given temporary release and those released on bail.305 Although none of the participants in the study appears to have received support on this basis, it appears that the power is sufficiently broadly drawn to allow the Secretary of State to provide support for stateless persons, particularly if she considers that their human rights would be breached if such support was not provided. This power could be used to ensure that those stateless persons who do not claim asylum and are not permitted to work avoid destitution and the social problems that can arise. However, none of the participants in the research benefited from the application of this provision to their situation. Evaluation of participants’ situations In conclusion, 11 of the 34 participants interviewed for this project had experienced rough sleeping or homelessness in the UK.306 Six of these 11 participants experienced homelessness after section 4 support was stopped or denied.307 Eight participants had been granted leave to enter or remain by the time that they were interviewed for this study. None of those with leave to enter or remain were homeless or destitute because the leave that they had been granted to not have restrictions on access to public funds. Two were in employment,308 two were in full time education309 and three were receiving welfare benefits or in the process of applying for these.310 The remaining 29 participants continued to live in limbo with no immediate prospect of being granted leave to enter or remain. 302 See AST 06/03/12859 and AST 07/11/16508 cited in, S. and Knapfler, S., op. cit., p. 282 and AST 10/05/23245, AST 09/07/20070. 303 AST 06/03/13043. 304 See UNHCR Geneva Summary Conclusions, para. 30. 305 Immigration Act 1999, section 4(1). 306 Participants 1, 4, 6, 10, 11, 17, 18, 26, 28, 29 and 36. 307 Participants 4, 11, 17, 18, 26 and 29. 308 Participants 23 and 37. 309 Participants 19 and 22. 310 Participants 8, 9, 28 and 33. in the United Kingdom 101