The intersection of race and nationality in Greece’s necropolitical violation of the right to life; the case of Safi and Others v. Greece


“This country has been dealing with the migration crisis of unprecedented intensity, has been saving hundreds, if not thousands, people at sea . . . while at the same time, yes, we are intercepting boats that come from Turkey, as we have the right to do in accordance to European Regulation . . . you should put the blame on others and not at us1 (Η ΑΥΓΗ Εφημερίδα της Αριστεράς, 2021).

This was the answer of Greece’s Prime Minister (PM) Kyriakos Mitsotakis in the straightforward question of the Dutch journalist Ingeborg Beugel, regarding the illegal pushbacks in the Aegean Sea. With this answer, the PM has indulged in a biopolitical rhetoric of who has the power to control the non – European lives sailing in the Aegean borders, who has the power to form policies around a foreign national’s right to life and a European state’s border sovereignty, and whose responsibility is it when this biopolitical control results to some ‘collateral damages’, i.e. the government’s action or inaction when it comes to the right to life of the Other.

In 2015, in a time of political and economical uncertainty, the European Union (EU) found itself in the difficult position of controlling and managing the increasing migratory and refugee inflows, originating primarily from the Middle East and Africa. Through a series of immigration and refugee policies and regulations, the EU has created the image of a ‘Fortress Europe’, in which migration is allowed and enhanced inside its internal borders, while the non – European incomers are harshly prevented from entering and staying in the European land, under the rhetoric of securitization of migration (for more see the Schengen Borders Code Regulation 2016/399 and the European Border and Coast Guard Agency – ‘FRONTEX’ Regulation 2016/1624). Since the Dublin III Regulation (604/2013/EU) determines that the first EU Member State, whom borders the foreign nationals cross, shall be responsible for the examination and control of the incoming asylum seeker, a political and humanitarian pressure has been put to the external European borders, that is the borders of Spain, Italy and Greece.

Notwithstanding, these attempts to control which lives should be subjugated outside and inside the European borders, this biopolitical (and necropolitical as it will be discussed later on) approach, has led to serious human rights violations, like in the case of Safi and Others v. Greece, as it will be studied in the final chapter.

Research question.

In this essay the following problematization will be discussed; how is race and nationality entangled in Greece’s necropolitical violation of the right to life? In more details, this research question will be constructed by other questions; what kind of racialized and nationalized bodies construct the Other in Greece, so their right to life can be exploited and dehumanized? What is the role of the human rights as an institution in this necropolitical arena? Is gender relative to this discussion? This research topic will be studied and unpacked and it will be applied in the case of Safi and Others v. Greece, judged by the European Court of Human Rights (ECrHR) on July 7, 2022.

Key concepts.

  • What kind of racialized and nationalized bodies construct the Other in Greece?

While race and nationality were both sensitive concepts for the geopolitical redefined, post – WWII and post – Nazi Europe, exclusionary immigration policies were nevertheless rising against the eastern Europeans. Being European was (and still is) interwoven with being White, but not any kind of White, rather the one originating from the west and the north (Rastas, 2019). Although, race and racism have taken many forms across the years, the unavoidable political trajectory around a state’s sovereignty often goes hand in hand with the identity of being native and a state’s national citizen. The interesting point here is that Eastern Europe became and, in a way, still is the European Other (but, nevertheless, it remains European). Although, many of the Eastern European countries are now part of the EU and the eurozone, many contradictory feelings about their whiteness, and hence Europeaness, were in the political surface in the post – WWII era.

Greece was never immune to the overwhelming glare of the globalized, neoliberal capital economy and the Europeaness this economy breathed. The state’s troubling historical and political past led to an impatient feeling of belonging to the West. At the end of the 20th century, the political agenda of the Greek governments was to be part of the then European Economic Community (EEC), and dismiss its non – European and non – White identity, a goal which was achieved in 1981 (Dalakoglou, 2013). “Greece, politically, defensively, economically, culturally, belongs to the West”, declared Karamanlis in 1976 (ΕΛΛΗΝΙΚΟ ΗΜΕΡΟΛΟΓΙΟ-ΕΛΛΗΝΟΪΣΤΟΡΕΙΝ, 2015). Racism against the Albanian migrants at the end of the 20th century, and some years later towards the migrants and refugees from Asia, Africa and the Middle East, shows that Greece had adopted its new identity as a white (?)2, European state and it could now play in an upgraded level in the globalized geopolitical power dynamics.

The “Others” became the non – Europeans, the non – whites, the non – Greeks, who “invade” the Greek territory (see ETHNOS, 2021; Kathimerini, 2020) and put in danger the pure “Greek – orthodox Nation” with their “dirty” efforts to “islamization and population alteration” (see, 2020). These are some of the main political and religious narratives that construct the Other in the Greek daily news. The incoming migrants and refugees can never be at home in a European territory, thus will always be othered, because as Tudor (2018) points out “thinking about racism in Europe only in terms of migration and national belonging, then, has the effect of racially homogenising Western/European nations as white and excluding Europeans of colour” (p. 1059). This means that other nationals and non – whites who attempt to “invade” this homogenization are not welcome, thus their lives are narrated as a threat to the natives’ lives, the national security and the state’s sovereignty (Mbembe, 2019). It is this narrative that leads to the necropolitical and racist agendas and the state’s imaginary belief of having the right to act in this way.

  • Necropolitics and Human Rights

Necropolitics is a term introduced by the Cameroonian political philosopher Achille Mbembe. This term is a complementary term to Foucault’s biopolitics, and refers to the “contemporary forms of subjugation of life to the power of death” (Mbembe, 2019, p. 92). It is the exercise of the political power that has control over the life, not only through the choice of who is allowed to live and who’s not, but also through the construction of the notion of life per se. This power, primarily motivated by racism, degrades the value of life of certain groups and the government acts in a state of exception, having the right to curtail or abrogate people’s constitutional rights. This state of exception is applied in certain, urgent periods of time. One such urgent period, which put Greece in a state of exception, could be the 2015 “refugee crisis”. For the necropolitical narrative:

“there is no one to blame for the suffering of that which becomes killable like an extinguished cigarette, except for the self-responsible willing individual. It is as though to kill slowly” (through intercepting refugee boats in the Aegean), “without bearing the responsibility for murderous laws and policies, is not only contingent on the possible threat that the killable subject poses to the population whose life is worth protecting, but it also requires desire and willingness on the killable subject’s part.” (Shakhsari, 2014, p. 93).

It is the willing refugees and migrants who choose to enter ‘Fortress Europe’ and thus put one’s government sovereignty in a state of exception, which needs to defend and protect itself from the political, national and religious intrusion. It is in our common imaginary representation of the other as they who are opposed to our democratic, christian and ethical values, and adopt their barbaric, un – democratic, terrorist values (Meliopoulos, 2022) which constructs a canonical image of the Other as less human and thus not worthy of their humanly rights.

Through the necropolitical narratives and practices the Others, the ones who become migrants and refugees in Greece are striped of their humanity and their inherent human rights. Human rights do not exist in a vacuum but rather the people who have (or not have) them and those who have the power to exercise them, exist in a specific geopolitical and historical position. For the German political philosopher Hannah Arendt, human rights are not just abstract notions that exist outside a state’s national and geographical sovereignty. The subject that can have human rights is the one that is bound by their surrounding political context and the state’s political agenda. In other words, the right to have rights depends on the political community which will willingly recognize the foreign migrant and refugee as someone who belongs in this community, thus they politically deserve to have rights and being protected. Human rights are instrumentalized as political weapons, as the American political scientist Clifford Bob argues, against the enemy that threatens a state’s sovereignty (Meliopoulos, 2022).

Having said that, under a necropolitical agenda, human rights are being ordered hierarchically (which is justified under the state of exception of the government) and are instrumentalized in order to prioritize the protection of the existence and interests of certain national groups, so as the state’s national and geopolitical sovereignty can remain untouched. Finally, the right to life is just another political arena for the state in order to justify its necropolitical actions and in – actions towards the non – nationals, whose right to life hinders the state’s political interests and for that, it needs to be reconstructed as less valued. “Non-citizen populations are assumed to be outside of the state’s responsibility in a way that citizens are not, and it is this logic that continues to legitimize the idea that ‘states can, and in many respects should, treat their citizens differently from foreigners” (Rygiel, 2016, p. 548).

  • Is gender relative to this discussion?

When politics are discussed, gender is always relevant. Under the racist political rhetoric that sees migrants, first and foremost, as political subjects that invade the nation and they alter it through their racialized, uncontrolled reproduction, the national and cultural cohesion is considered under threat. Positions of political power and influence that are held primarily (if not exclusively) by white, European (or at least western), men, are irrigated with narratives of custodian responsibility for the nation’s homogeneity, i.e. the white, European, christian identity. It is the racialized generational reproduction of the nation that consists a problem under the biopolitical agenda. As Umut Erel (2018), an English sociologist, points out “women play an important role in constructing national identities: on one hand as symbols of the nation, embodying its values, on the other, in their role as mothers, women transmit culture and values to the next generation, as well as biologically reproducing the group” (p. 174). Women are seen as carrying the future of the nation, through their national and racial purity, which needs to be protected by the state. On the other side of the coin, men are portrayed as “the modernising and progressive aspects of the nation” (p. 174). This gendered narrative is very much relevant to the racialized necropolitical actions of the state. Migrant women’s reproductive activity threatens the national homogeneity, while men as carriers of cultural and religious heritage, are approached with hostility and are being marginalized. In both cases, their lives are less valued and not protected, their rights are not recognized, and they are literally in between life and death (when death is not literally there), since they cannot fully exercise their right to life.

The case of Safi and Others v. Greece.

On July 7, 2022 the European Court of Human Rights (ECrHR) unanimously condemned Greece for the sinking of a fishing boat on January 20, 2014 which was transferring 27 foreign nationals, 11 of whom lost their lives in the sea. According to the applicants, the Greek coastguard vessel was trying to push (or rather intercept?) the fishing boat back to the Turkish waters (as they had the right to do?) by increasing speed, resulting to the overturn of the boat. The applicants were nationals of Afghanistan, Syria and Palestine. The ECrHR judged that there had been a violation of Article 2 of the European Convention of Human Rights (ECHR) (right to life) and of Article 3 (prohibition of inhuman or degrading treatment) (European Court of Human Rights, 2022).

In more details, the ECrHR condemned the Greek state for not providing the adequate response to the incident of the sinking boat, for not taking into serious consideration the risk for the passengers’ lives, for not conducting the proper investigation for their deaths and for re – victimizing the survivors by imposing them to body searches. Under this inadequate response of the Greek Coast Guard Agency, eight children and three women, some of them being relatives of the applicants, lost their lives. The substantive aspect of the right to life was violated, according to the Court, since there was no adequate explanation of the Greek Coast Guard Agency to use a speed boat which was lacking the appropriate rescuing equipment and to not act in time, since they were informed of the incident immediately. Yet, they arrived at the scene over an hour later (Katsoni, 2022).

The bodies of the dead carry political meanings through their existence and non – existence, through their suffering and the way they lost their lives, through the constitutional position of ignorance and remissness by the state. The fact that the people who survived and those who lost their lives in the Safi and Others case, were all nationals from Afghanistan, Syria and Palestine is an accurate example of the exclusionary, racialized political agenda of the Greek state. Through a necropolitical point of view, these nationals, being all people of color, with no national and/or race connections to Greece or Europe, were recognized as a political threat by their “illegal” transnational movement. The bodies of these dead carry a plethora of political meanings, since they were all women and children, thus they breathed a continuity of life; non – European women who would be reproductive inside the European borders and they would claim their rights as mothers carrying a European citizen, and children whose life could not have yet carry a concrete political identity, thus it could be formed inside the European borders with all the subsequent rights this implies. The Greek state found itself in a state of exception, being threatened by their racialized presence, and decided to not recognize them as political subjects who belong in Greece’s political community. Thus they do not have the right to claim their rights and be protected.


“I thank Greece for acting as the shield of Europe”, said Von der Leyen, the President of the European Commission at the end of her visit to the area (Evros) (Mascarenas, 2021, p.7)

“Greece has become a dumping ground for the men, women, and children that the European Union has failed to protect. What was once touted as a ‘refugee emergency’ has given way to inexcusable levels of human suffering across the Greek islands and on mainland Greece. The EU and Greek authorities continue to rob vulnerable people of their dignity and health, seemingly in an effort to deter others from coming. This policy is cruel, inhumane, and cynical, and it needs to end.” (Doctors Without Borders/Médecins Sans Frontières (MSF), 2022)

I decided to close this essay with these two contradictory quotes. While politicians narrate a political reality that suits them better, the reality of the people living it has some serious human rights violations. Although Greece’s racial identity could still be in the verge of adopting whiteness, by entering EU this verge took a political turn to the European identity, which is bound together with the coveted whiteness. Greece is one of the external borders of Europe, a geopolitical position which is embedded with the responsibility of protecting the racial and national homogeneity of Europe by protecting the racial and national homogeneity of the Greek state itself. In this political agenda, the non – white, non – European, migrants and refugees become the Other, whose rights are narrowed, if not dismissed at all, once they (try to) enter “Fortress Europe”. The Aegean Sea is the invisible geopolitical arena in which the state fights for its sovereignty, in a state of exception. Non – white and non – European people’s attempts to migrate to Greece and Europe are automatically considered illegal, invasive and threatening for the nation’s integrity. A combination of racism, Islamophobia and racism, construct the pieces of the necropolitical actions of Greece’s government.

Eleven Afghan, Syrian and Palestinian women and children, in the case of Safi and Others, lost their lives in an attempt of intercepting their boat by the Greek Coast Guard Agency. At the beginning of this essay, PM Kiriakos Mitsotakis claimed that Greece has the right to intercept non – nationals boats in the Aegean Sea, a right which has been given by the EU itself. “You should put the blame on others not us”, a blame which no political organization, no Western state, no European government wants to take. Finally, this necropolitical game, isn’t it always an institutional game between the life of the state itself and the lives of the migrants and refugees? How these power dynamics can be overturned?

Reference list.

Dalakoglou, D. (2013). ‘From the Bottom of the Aegean Sea’ to Golden Dawn: Security, Xenophobia, and the Politics of Hate in Greece. Studies in Ethnicity and Nationalism, 13(3), 514–522.

Doctors Without Borders/Médecins Sans Frontières (MSF). (2022, March 11). Greece: Three years of “cruel, inhumane, and cynical” treatment of migrants and refugees. Doctors Without Borders – USA.

Erel, U. (2018). Saving and reproducing the nation: Struggles around right-wing politics of social reproduction, gender and race in austerity Europe. Women’s Studies International Forum, 68, 173–182.

ETHNOS. (2021, April 5). Έβρος: Συναγερμός για νέα εισβολή μεταναστών από Τουρκία. ΕΘΝΟΣ.

European Court of Human Rights. (2022, July 7). Violations of the Convention in a case concerning the sinking of a migrant boat [Press release].

Kapetopoulos, F. (2016, October 31). When did I become ‘white’? NEOS KOSMOS.

Kathimerini. (2020, February 29). Σε συναγερμό οι αρχές για να αποτρέψουν «εισβολή» μεταναστών – Ενισχύονται οι δυνάμεις της ΕΛΑΣ στον Εβρο. ΚΑΘΗΜΕΡΙΝΕΣ ΕΚΔΟΣΕΙΣ ΜΟΝΟΠΡΟΣΩΠΗ Α.Ε. Εθν.Μακαρίου & Φαληρέως 2.

Katsoni, S. (2022, September 7). How to Get Away with Refoulement: Some Thoughts on Safi and Others v. Greece. Strasbourg Observers.

Mbembe, A. (2019). Necropolitics. In Necropolitics (pp. 66–92). Duke University Press.

Meliopoulos, G. (2022). Δικαιώματα και Νεκροπολιτική: η διαχείριση της προσφυγικής κρίσης στην Ελλάδα (2015-2022) [Rights and Necropolitics: the management of the refugee crisis in Greece (2015-2022)] [MA Thesis]. Aristotle University of Thessaloniki. (2020, January 11). Αδωνις: Οι μετανάστες αλλοιώνουν τη χώρα. [Adonis. Migrants alter the country]

Rastas, A. (2019). The Emergence of Race as a Social Category in Northern Europe. In P. Essed, K. Farquharson, K. Pillay, & E. White (Eds.), Relating Worlds of Racism (pp. 357–381). Palgrave Macmillan, Cham.

Rygiel, K. (2016). Dying to live: migrant deaths and citizenship politics along European borders: transgressions, disruptions, and mobilizations. Citizenship Studies, 20(5), 545–560.

Shakhsari, S. (2014). Killing me softly with your rights: Queer death and the politics of rightful killing. In Queer Necropolitics (pp. 93-110). Taylor and Francis.

Tudor, A. (2018). Cross-fadings of racialisation and migratisation: the postcolonial turn in Western European gender and migration studies. Gender, Place &Amp; Culture, 25(7), 1057–1072.

ΕΛΛΗΝΙΚΟ ΗΜΕΡΟΛΟΓΙΟ-ΕΛΛΗΝΟΪΣΤΟΡΕΙΝ. (2015, June 11). Η ΕΛΛΑΣ ΑΝΗΚΕΙ ΕΙΣ ΤΗΝ ΔΥΣΙΝ (Κ.ΚΑΡΑΜΑΝΛΗΣ [Greece belongs to West] 12/6/1976) [Video]. YouTube.

Η ΑΥΓΗ Εφημερίδα της Αριστεράς. (2021, November 9). Άγριο επεισόδιο Μητσοτάκη με Ολλανδή δημοσιογράφο. [Mitsotakis wild episode with a Dutch journalist] [Video]. YouTube.

1emphasis added by the author.

2This is actually a complex identity to adopt for the Greeks, Kapetopoulos (2016) describes it vividly in his article “When did I become ‘white’?”.

By Φαίδρα Γατσαρούλη

My name is Faidra Gatsarouli. I am a psychology graduate from the Aristotle University of Thessaloniki and a master’s student in Human Rights and Migration Studies and in Gender, Justice and Society in the University of Macedonia and Umea University, respectively. I'm particularly interested in research on feminist and gender studies, women’s rights and the LGBTQ+ community, the intersectional migration and refugee experience and the psychological well-being of the nontraditional family structure. Besides my academic aspirations, I really love art, photography. solo travelling and reading contemporary fiction.

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