Language barriers In Bulgaria, the applicant bears the cost of interpretation if required in the SDP. In Italy, interpreters are not provided for hearings in the judicial procedure. In the United Kingdom, interpreting services are available for interviews (which only take place if the decision-maker cannot decide based on the written application), but no translation or interpreting is provided for other stages of the application process or for communication with legal representatives representatives unless the applicant has qualified for legal aid. Lack of access to an interview In Italy, in the judicial procedure, hearings will take place, but there is no provision ensuring interpreters are provided, although they may be present on request. In Latvia, France, and the United Kingdom, interviews are permitted but only take place in certain circumstances, usually where the decision-maker requires further information. In the United Kingdom, there are examples of applications being refused where an interview could have been sought, as well as applicants being unable to attend interviews due to travel costs.64 Delays and errors in decision-making In many countries, long delays are reported, which often exceed established time limits. In Bulgaria, cases of ‘silent rejection’ have been reported whereby the six-month time limit expires without a decision being communicated. In Italy, despite the very long 895-day time limit in the administrative procedure, cases are known to last much longer than this, with the longest reported to have lasted 13 years. In France, there is no time limit for decisions resulting in long delays up to two or three years. In the United Kingdom, initial decisions are reported to take up to two years, although guidance requires a new decision following administrative review to be made within three months. There are also reports of errors in decision-making, including in the United Kingdom, Spain, Bulgaria, and Hungary. In Spain, some decisions have failed to implement judicial decisions, and in the United Kingdom, errors reported include a failure to examine relevant evidence or to determine statelessness prior to excluding applicants on grounds of criminality. A common error in several countries relates to the treatment of stateless Palestinians. In Bulgaria, applications from Palestinians are reportedly automatically rejected without a thorough individual examination on grounds that the Bulgarian Government recognises the State of Palestine. Similarly, in Hungary, the competent authority previously rejected applications by stateless Palestinians, referring to the recognition of the State of Palestine by the United Nations. This approach was successfully challenged through litigation in Hungary on grounds that there is no nationality law governing Palestinian nationality, so Palestinians cannot be considered nationals under the operation of the law of the State of Palestine. Across Europe, case law has been emerging from domestic and regional courts regarding the ability of UNRWA to fulfil its mission to provide protection or assistance in Gaza and Lebanon, and regarding its scope of operations, which could impact on stateless Palestinians’ eligibility for protection under the 1954 Convention and the 1951 Convention Relating to the Status of Refugees.65

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