See also BVerfGE 132 where in 2012 the court went beyond the procedural protection in the previous case and recognised a substantive element to an adequate level of subsistence for asylum seekers relying on Article 9 ICESCR. 13 See Trojani Case C-456/02 (an EU case guaranteeing access to minimum social assistance under the free movement of workers). 14 Similarly, the Swiss Federal Court has found that an implied constitutional right to a ‘minimum level of subsistence (‘conditions minimales d’existence’), both for Swiss nationals and foreigners, could be enforced by the Swiss Courts. See Swiss Federal Court, V...