40 AUAD v. BULGARIA JUDGMENT was arrested with a view to deportation less than a month after that, on 17 November 2009 (see paragraphs 8-13 and 15 above). He cannot therefore be regarded as a settled migrant who has developed a private life in Bulgaria (contrast Maslov v. Austria [GC], no. 1638/03, § 63, 23 June 2008, and Miah v. the United Kingdom (dec.), no. 53080/07, § 17, 27 April 2010). On the contrary, his stay in Bulgaria has been brief and at all times precarious (see, mutatis mutandis, N.M. and M.M. v. the United Kingdom (dec.), nos. 38851/09 and 39128/09, 25 January 2011). Article 8 is not therefore applicable. 112. It follows that this complaint is incompatible ratione materiae with the provisions of the Convention within the meaning of Article 35 § 3 (a) and must be rejected in accordance with Article 35 § 4. III. ALLEGED VIOLATION OF ARTICLE 13 OF THE CONVENTION 113. The applicant complained under Article 13 in conjunction with Articles 3 and 8 of the Convention that the Supreme Administrative Court had not genuinely scrutinised whether he represented a risk for national security, had refused to examine whether he would risk ill-treatment or death if expelled to Lebanon, and had not considered whether such expulsion would be proportionate. 114. 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 115. The Government submitted that the applicant had been able to challenge the order for his expulsion in judicial review proceedings, in the course of which he had been able to acquaint himself with all documents in the case file and seek to rebut the assertions of the authorities. In judicial review proceedings, the courts reviewed whether the administrative decision had been issued by a competent authority, in due form, and in compliance with the rules of administrative procedure and substantive law. In the applicant’s case, the Supreme Administrative Court had done just that. It had examined the arguments of the parties and had given reasons for finding against the applicant. It is true that the question whether the applicant faced a risk of ill-treatment upon expulsion had been raised before that court. However, since the proceedings concerned the lawfulness of the expulsion order, the court had deemed that question to be irrelevant. Domestic courts could review only specific administrative decisions. The applicant did not