• non-refoulement
• migration
• Italian asylum law
• EU asylum law
• discretionary leave
• British asylum law
• protezione umanitaria

The present work seeks to offer an analysis of national schemes of protection for vulnerable persons, by focusing on two main countries, the United Kingdom and Italy. The aim is to critically compare their national schemes of protection, which are added to protections regulated by EU asylum law and to understand their nature and function. Particularly, the evaluation is intended to bring out the reasons for granting such forms of protection and their potential international basis. Moreover, the study wants to show their scope and role in Italian and British asylum systems, without overlooking other EU Member States. Indeed, the present enquiry has revealed the need for referring also to other selected EU Member States, such as Denmark, Sweden and Germany, in order to stress the broad significance of these schemes of protection in the European Union context. Finally, the work attempts to draw attention to recent reforms adopted in the countries above mentioned, since they show some legal and political common trends.