Kernrechtsfrage
Whether a criminal conviction alone constitutes a concrete indication under Art. 13b(1) ANAG that the foreign national seeks to evade removal.
Extrahierter Entscheid
No. A criminal conviction may be an indication of increased non-compliance with official orders, but not every conviction is a concrete sign of intended evasion of removal.
Extrahierte Begründung
The court held that, although a convicted foreign national may more readily be expected to disregard official orders, criminal liability by itself does not automatically establish the statutory detention ground. Additional circumstances are required.