MS (Coptic Christians) Egypt CG 2013
This is a country guidance case and it stated the following point:
1). Notwithstanding that there is inadequate state protection of Coptic Christians in Egypt, they are not at general risk of persecution or ill-treatment contrary to Article 3 ECHR.
2). However, on current evidence there are some areas where Coptic Christians will face a real risk of persecution or ill-treatment contrary to Article 3.
In general these will be:
a. Areas outside the large cities
b. Where radical Islamists have a strong foothold and
c. There have been recent attacks on Coptic Christians or their churches, businesses or properties.
3). On the evidence before the Upper Tribunal the following are particular risk categories, in the sense that those falling within them will generally be able to show a real risk of persecution or treatment contrary to Article 3 in their home area:
i. Converts to Coptic Christianity
ii. Persons who are involved in construction or re-construction/repair of churches that have been targeted for attack or attacks
iii. Those accused of Proselytising where the accusation is serious and not casual
iv. Those accused of being physically or emotionally involved with a Muslim woman, where the accusation is made seriously and not casually
v. Coptic Christian women in Egypt, are not in general at risk of persecution or ill-treatment, although they face difficulties additional to other women, in the form of sometimes being the target of disappearance, forced abduction and forced conversion
vi. Depending on the particular circumstances of the case, Coptic Christian women in Egypt aged between 14-25 years who lack a male protector, may be at such risk.
vii. If a claimant is able to establish that in their home area they fall within one or more of the risk categories identified in 3(ii)(iv) above or that they come from an area where the local Coptic population faces a real risk of persecution, it will not necessarily follow that they qualify as refugees or as beneficiaries of subsidiary protection or Article 3 ECHR protection. That would depend on whether they can show that they would not have a viable internal relocation alternative. In such cases there would be a need for a fact specific assessment, but in general terms, resettlement in an area where Islamists are not strong would appear to be a viable option.
viii. None of the above necessarily preclude a Coptic Christian in Egypt from being able to establish a real risk of persecution or ill-treatment in the particular circumstances of their case.