Key legal question
Whether the conditions for removal detention under Art. 13b ANAG were met, especially absconding risk.
Extracted holding
Yes. His false identity, criminal conduct, disappearance from his assigned residence, and repeated refusal to return to Benin showed a concrete risk of absconding.
Extracted reasoning
The court held that prior disappearance, deceptive statements, criminality and refusal to cooperate normally establish flight risk; therefore detention was justified.