rights instruments are relevant to the expulsion of stateless persons from a territory.148 Like other provisions of the 1954 Convention, Article 31 must be read in light of UNHCR’s interpretations of the “lawfully staying” and related provisions, discussed above. In Sweden, the grounds for the expulsion of aliens, including stateless persons, are set out in Chapter 8 of the Aliens Act. A decision on refusal of entry of a rejected asylum-seeker can be implemented immediately, without suspensive effect of appeal, if the asylum application has been determined to be manifestly unfounded and there are no other reasons for granting a residence permit (Section 6). In accordance with Chapter 8, Section 18 of the Aliens Act, a decision on refusal of entry or expulsion shall indicate the country of return. If there are specific reasons for it, more than one country may be indicated in the decision. This reference to the country of return has no legal effect in itself, but only defines the country or countries to which the person is considered to have a possibility to return.149 Chapter 12, Section 1 of the Aliens Act states that return of a person can never be implemented to a country where there are reasons to believe that the person would be at risk of the death penalty, corporal punishment, torture or other inhuman or degrading treatment or punishment. This provision also protects a person from being returned to a country from which he or she could be sent further, to a country in which the person would be subjected to such ill-treatment (chain-refoulement). In this context, it is noteworthy that Sweden implements decisions on expulsion of rejected Palestinian asylum-seekers whose habitual residence is considered to be Gaza, through Egypt, provided the person concerned is granted a transit visa for Egypt.150 However, no assessment is made regarding potential protection problems such Palestinians may face while in transit in Egypt, such as arbitrary detention.151 One of the decisions reviewed by the consultant concerns the return of a stateless Palestinian from Jordan who had been refused asylum in Sweden. The individual had initially not presented identity documents and, according to the SMA, had not cooperated in the implementation of the return decision. Therefore, the decision could not be implemented. Two years after the return decision was made, the person presented a Palestinian passport issued by the Jordanian authorities; shortly thereafter, he was returned to Jordan with his consent and without an escort. However, he was not admitted into Jordan, and therefore returned to Sweden.152 The Swedish Embassy in Jordan subsequently informed the SMA that the person had a temporary Jordanian passport, but was not a Jordanian national and did not have a permit to enter the country. It was considered that after the person presented his Palestinian passport, he had cooperated with the authorities in order to implement the return decision. As the SMA determined that the obstacle for the implementation of the return would persist, the person was granted a permanent residence permit on the grounds of particularly distressing circumstances, pursuant to Chapter 5, Section 6 of the Aliens Act.153 Table 7 below provides an overview of the number of stateless persons who returned voluntarily, or with the use of force, during 2015. 148 See, e.g., UNHCR, Handbook, noting that “protection against expulsion for persons ‘lawfully in’ the territory is confined under Article 13 of the ICCPR to procedural safeguards, whereas Article 31 of the 1954 Convention also limits the substantive grounds on which expulsion can be justified.” 149 Chapter 12, Section 4 of the Aliens Act. 150 Telephone conversation with the SMA, 7 September 2012; see also Migrationsverket, Lifos. Center för landinformation och landanalys inom migrationsområdet, Temarapport: Gränsövergången i Rafah – status, kriterier och proceduren vid passage till och från Egypten, (Thematic report about the functioning of the border crossing point at Rafah), 20 February 2015. 151 Meeting with Amnesty International, 25 September 2012, and with the Swedish Refugee Advice Centre, 19 September 2012, which also confirmed the continued accuracy of the statement during a telephone conversation, 19 April 2016. 152 The decision does not mention whether the person was returned by Jordan or whether the person returned by himself. 153 Chapter 5, Section 6 of the Aliens Act states that if a residence permit cannot be granted on other grounds, a permit can be granted if in the total assessment of the alien’s situation there are such particular compassionate circumstances that he or she should be permitted to stay in Sweden. In the assessment particular account is taken of the alien’s health, adaptation to Sweden and the situation in the home country. UNHCR STOCKHOLM, 2016 45