Question juridique clé
Whether immigration detention under Art. 13b ANAG was lawful because there was a risk of absconding and lack of cooperation in obtaining travel documents.
Solution extraite
Yes. The appellant repeatedly failed to cooperate, used false identity details, and showed no willingness to return, so there was a sufficient risk of absconding.
Motifs extraits
Passive non-cooperation in obtaining documents can satisfy the statutory detention ground. The appellant had misled authorities about his identity, did not assist with paperwork, and his prior movements did not amount to a completed departure preventing detention.