Question juridique clé
Whether the removal detention under Art. 13b ANAG was lawful because of a risk of absconding.
Solution extraite
Yes. The appellant's conduct showed he was unlikely to remain available for removal proceedings without detention.
Motifs extraits
Repeated non-compliance with departure requests, limited cooperation, prior disciplinary and criminal conduct, contradictory statements about travel documents, and weak attachment to family members in Switzerland justified a finding of absconding risk.