Judgment and decision in passport cases

Question on what constitutes special reasons for granting an application for a regular passport when, within five years prior to the application, three regular passports have been issued for the applicant.

A Swedish citizen is entitled to apply to obtain a regular passport if there are no impediments to it. An application for a regular passport is to be rejected where, within five years prior to the application, three regular passports have been issued for the applicant and there are no special reasons to grant the application. In two cases, the Supreme Administrative Court has examined whether there were such special reasons.

The Supreme Administrative Court emphasized that the determination of whether special reasons exist to grant an application for a fourth regular passport within a five-year period shall be made on the basis of all circumstances in the individual case and that it is of special importance why the previous passports can no longer be used and whether there is a risk that previous passports could have been abused. The applicant's need for an ordinary passport should also be considered. According to the Supreme Administrative Court, the fact that there are circumstances which suggest that the applicant did not treat previous passports as documents of value suggests the absence of special reasons in the individual case. However, the fact that the applicant had been careless with a passport on individual occasions did not exclude the presence of special reasons.

In one case, the Supreme Administrative Court found that there were special reasons to grant the application. In that case, a previous passport had needed to be replaced because the applicant had changed his name, a passport had been lost at an airport and a passport had been damaged in connection with a fire at a hotel.

In the second case, the Supreme Administrative Court found that there were no special reasons to grant the application. The applicant in that case had stated that his three previous passports had been stolen and that he had a great need for a regular passport, inter alia because he lives abroad and travels a lot for work. The Supreme Administrative Court found that one passport had probably been stolen but that it was not possible to draw any firm conclusions about what had happened to the other passports and that it was clear that the applicant had not cared for his passports in a secure manner nor handled them with due care. Although possession of a regular passport would make it easier for the applicant to perform his work, the Supreme Administrative Court considered that it could not be deemed unreasonable to not issue one for him.

Updated
2025-01-09