After nearly 25 years of consistent legal representation led by attorney Dr Valeria Ilareva, almost three decades of life in Bulgaria in legal limbo and a breakthrough of European significance in the strategic case Changu (C-352/23), Kasim Changu, a Tanzanian national, now has humanitarian status and a Bulgarian identity card for foreigners. Following the recognition of humanitarian status in the summer of 2026, he received his identity document in September — an important practical step towards normalising his life.
Kasim Changu’s story is one of exceptionally long patience, persistent legal advocacy and the power of fundamental human rights. It also shows how a single individual case can contribute to the development of case law across the entire European Union. In the video interview accompanying this publication, attorney Dr Valeria Ilareva speaks about the legal limbo in which he lived for decades and about the significance of the case.
Kasim Changu arrived in Bulgaria in 1996 without identity documents. Over the following decades he lodged eleven applications for international protection, which were repeatedly rejected. He was detained more than once with a view to his forced return to Tanzania, but the return was never carried out because the necessary documents were lacking. Despite his cooperation with the authorities, including his stated wish to return voluntarily, he remained in Bulgaria with no way of regularising his stay.
Kasim Changu thus found himself in a legal limbo: the State was unable to return him to his country of origin, yet national legislation offered no applicable mechanism to regularise his situation. Without documents or the right to work, without access to basic social rights and with deteriorating health, he spent decades in extreme material insecurity.
From Bulgaria to the Court of Justice of the European Union
The breakthrough came with the eleventh application for international protection, lodged in April 2021. After yet another refusal by the State Agency for Refugees (SAR), the case reached the Administrative Court of Sofia City, which by an order of 29 May 2023 made a request for a preliminary ruling to the Court of Justice of the European Union.
On 12 September 2024, the Court of Justice delivered its judgment in Changu (C-352/23).
The Court clarified that, although EU law does not in itself require Member States to grant a right of residence to every third-country national whose return is impossible, such persons continue to enjoy the guarantees of fundamental rights, including those under the Charter of Fundamental Rights of the EU and the Return Directive.
The judgment also confirms that Member States may grant protection and a right of residence on humanitarian grounds under their national law, separately from the international protection governed by EU law.
On 12 November 2024, the Administrative Court of Sofia City annulled the refusal to grant humanitarian status for other reasons of a humanitarian nature. The court found that Kasim Changu had fallen into a situation of extreme material deprivation incompatible with human dignity and the protection against inhuman and degrading treatment.
On 23 April 2025, the Supreme Administrative Court upheld this judgment with final effect. It held that Kasim Changu’s situation amounted to a legal limbo and that Bulgaria was under an obligation to ensure respect for his fundamental rights. The court confirmed the applicability of the national provision allowing humanitarian status to be granted for other reasons of a humanitarian nature.
From court victory to status and ID card
Despite the final judgment, the road to status did not end there. After a new refusal by the SAR, further court proceedings were needed. The Administrative Court of Sofia City again annulled the refusal, and in June 2026 the Supreme Administrative Court upheld that judgment.
In compliance with the binding court instructions, in July 2026 the Chairperson of the SAR granted Kasim Changu humanitarian status under Article 9(8) of the Bulgarian Asylum and Refugees Act. Attorney Yanka Kosarova of the Foundation for Access to Rights (FAR) then assisted him with his address registration and the issuance of an identity document. In September 2026, Kasim finally received his identity card for foreigners. The court victory thus also became a real change in his everyday life.
25 years, many lost battles and one victory
“Kasim has been granted status. It’s hard to believe, but after nearly 25 years of working on his case, I can now say it as a fact. It is a fact!”
These are the words of attorney Dr Valeria Ilareva, Chairperson of the Foundation for Access to Rights – FAR and lead counsel in the case throughout. She began working with Kasim as a student at the Legal Clinic for Refugees and Immigrants at Sofia University and went on to lead his legal representation and the work of the teams involved, later within FAR.
“I don’t remember the exact day I met him, more than 20 years ago. But I remember that Kasim always listened to me. Even now he strictly follows what I tell him. He gives me feedback. And he doesn’t give up.”
Under the leadership of attorney Ilareva, students from the Legal Clinic and attorneys from FAR have been involved in the legal representation over the years. The most recent court proceedings were conducted directly by attorney Kaloyan Stoyanov of FAR, who also took steps to have a sanction imposed for non-compliance with the final judgment. After the status was granted, attorney Yanka Kosarova of FAR assisted Kasim with his address registration and with obtaining his identity card in September.
Since 2022, free legal aid in the case has been provided with the financial support of the UN Refugee Agency (UNHCR) in Bulgaria.
A judgment with significance beyond the individual case
Kasim Changu’s story matters far beyond his personal fate. Across the European Union there are people who have no legal residence but who, for objective reasons, cannot be returned to their countries of origin. They may remain in legal uncertainty for years, with no real possibility of regularising their situation.
The Changu case helps clarify the obligations of States towards people trapped in legal limbo and affirms fundamental rights as a safeguard against extreme social exclusion. Its practical significance is already visible in many other court proceedings across the EU. For example, attorney Dr Valeria Ilareva is currently relying on the Court of Justice’s judgment in Changu in defending Abdul Karim — a refugee from Syria living with cancer, who is likewise in legal limbo in Bulgaria, without documents or any way of regularising his stay.
Kasim Changu’s case reminds us that human dignity and fundamental rights belong to every person, regardless of nationality or administrative status. Respecting them is an obligation of the State and a founding value of the European Union.
Kasim Changu’s story shows that, even after decades of effort, the law can find a solution where for a long time there seemed to be none. In the video interview accompanying this publication, attorney Dr Valeria Ilareva speaks further about the legal issues and the path of this case. We thank Bozhidar Ivanov and Jovana Ostojic of the Finding Agreement in Return (FAiR) project for the interview.
Key judgments and administrative decisions in the case
- Administrative Court of Sofia City — Judgment No. 6996 of 25.11.2021 in administrative case No. 5139/2021, First Division, 12th panel, annulling SAR Decision No. 9-OK of 29.04.2021 refusing to admit the eleventh application for protection to the regular procedure.
- Administrative Court of Sofia City — Order No. 4504 of 29.05.2023 in administrative case No. 9280/2022, First Division, 69th panel (request for a preliminary ruling to the Court of Justice of the EU).
- Court of Justice of the European Union — Judgment of 12.09.2024 in Case C-352/23, Changu.
- Administrative Court of Sofia City — Judgment No. 23209 of 12.11.2024 in administrative case No. 9280/2022, First Division, 69th panel.
- Supreme Administrative Court — Judgment No. 4263 of 23.04.2025 in administrative case No. 94/2025, Third Division.
- Administrative Court of Sofia City — Judgment No. 42974 of 22.12.2025 in administrative case No. 11196/2025, Second Division, 27th panel.
- Supreme Administrative Court — Judgment No. 6020 of 03.06.2026 in administrative case No. 2452/2026, Sixth Division.
