Proteção internacional dos migrantes vulneráveis. Um estudo comparativo entre o Sistema Europeu Comum de Asilo (SECA) e o Plano de Ação do Brasil (PAB)

This article proposes an analysis of the management of immigration and respect for the human rights of refugees in Europe and Latin America during the period 2015-2024, through a comparative look at the Common European Asylum System (CEAS) and the Brazil Action Plan (BAP), which, although different in many respects, share the 1951 Geneva Convention relating to the Status of Refugees and the Universal Declaration on Human Rights as central norms and the axis of their management. In this way, the theoretical assumptions underpinning the legal analysis of the issues of international protection, migration, refuge and human rights are outlined, and then transferred to the study of the reality of two areas that have become fundamental scenarios of migratory crisis, namely Latin America and the Caribbean, and the European Union. The adoption of this analytical perspective will ultimately make it possible to point out the greater or lesser suitability of the aforementioned models of migration management with respect for human rights. In short, this is an indispensable task, given that we find ourselves in an international socio-political reality plagued by conflicts, simultaneous violations of fundamental rights and global crisis, as shown by the avalanches of people who crowd the different border crossings of Europe and Latin America, some of them as deadly as the Mediterranean Sea or the Darien jungle.