Key legal question
Whether the immigration detention under Art. 13b ANAG was lawful and proportionate.
Extracted holding
The detention was lawful because the appellant had been validly removed, had not left Switzerland, refused to return, and his conduct established a concrete risk of absconding; the other detention prerequisites were also met.
Extracted reasoning
Repeated criminality, disregard for legal orders, and failure to take steps to obtain travel documents supported a risk of absconding. Removal to Angola remained realistically organizable and the authorities acted with due diligence.