Question juridique clé
Whether the extension of deportation detention was lawful and proportionate under the risk-of-flight and non-cooperation grounds.
Solution extraite
The extension was lawful: the appellant remained non-cooperative, removal to Côte d'Ivoire was still feasible, and no milder measure secured execution.
Motifs extraits
He persistently refused return, had already frustrated escorted removal by manipulating his health, travel documents still existed, and regular cell checks could prevent renewed medical obstruction. His prior conduct showed he would likely abscond if released.