1601521 (Refugee)

1601521 (Refugee) [2017] AATA 2140 (24 October 2017)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  1601521
COUNTRY OF REFERENCE:                  Ghana
MEMBER:Meena Sripathy
DATE:24 October 2017
PLACE OF DECISION:  Sydney
DECISION:The Tribunal affirms the decision not to grant the applicant a Protection visa.

Statement made on 24 October 2017 at 4:46pm
CATCHWORDS
Refugee – Protection visa – Ghana – Ethnicity – Akan tribe – Religion – Catholic – Social group – Chief of Akan tribe – Chieftaincy Issues – Fear of local tribe – Credibility Issues
LEGISLATION
Migration Act 1958, ss 36, 65, 91R, 91S, 499
CASES
MIMA v Rajalingam (1993) FCR 220
Selvadurai v MIEA& Anor (1994) 34 ALD 347
Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 431 of the Migration Act 1958 and replaced with generic information which does not allow the identification of an applicant, or their relative or other dependant.
STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Immigration to refuse to grant the applicant a Protection visa under s.65 of the Migration Act 1958 (the Act).
The applicant who claims to be a citizen of Ghana, applied for the visa [in] October 2014 and the delegate refused to grant the visa [in] January 2016.
The applicant appeared before the Tribunal on 4 September 2017 to give evidence and present arguments. The Tribunal hearing was conducted with the assistance of an interpreter in the Akan (Ghana) and English languages. The applicant was represented in relation to the review by his registered migration agent.
The issues in this case are whether the applicant has a well-founded fear of persecution in Ghana for one or more of the five reasons set out in the Refugees Convention (s36(2)(a)); and, if not, whether there are substantial grounds for believing that, as a necessary and foreseeable consequence of him being removed from Australia to Ghana there is a real risk that he will suffer significant harm (s.36(2)(aa)).
For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
CONSIDERATION OF CLAIMS AND EVIDENCE
Information in the application form indicates the applicant is [age] old man of Ghanaian nationality. He is from the Akan tribe. He is married and has [children], aged [ages]. He also has a mother and [siblings]. All of his family members reside in Ghana. He is tertiary educated, holding a [diploma] and indicates past employment in Ghana as [Occupation 1] from 2006 to July 2014. He arrived in Australia in July 2014 on a [temporary] visa to attend a [conference] in [City 1]. He previously travelled to [Country 1] in April 2014 for a business visit. He provides two addresses in Ghana, one in Accra from birth to 2014 and another in [the] Eastern Region, from 2001 to 2014.
He seeks protection from Australia from returning to Ghana because he fears harm from the people of [Village 1] where he is the local chief. He claims people have vowed to kill him because he has failed to return to his village to celebrate an annual festival in August and they believe he has disappointed and brought shame to the Chieftaincy and elders of the village. He claims as a Christian he is against the festival because of its association with pagan practices and rituals. The applicant claims he was forced to become chief of his village against his will when he was locked in a room and held for 7 days without adequate food and water in January 2013. Since being in Australia he claims he has renounced and abdicated his position as chief and has been attending church freely, without worry of having to perform pagan rituals associated with being Chief of [Village 1].
He claims during his absence from Ghana his wife and children have been assaulted by people from the village. His wife told him she knew one of the people who assaulted their children as she recognised them from when he took her to the village in the past. He claims they have threatened to kill his wife and children if the applicant does not return to Ghana and renounce his Christian beliefs. He claims his wife reported the grievous bodily harm she suffered to the police and sought medical assistance for her injuries. The applicant states he has chosen to practice his Christian faith over pagan rituals and the chieftaincy. He fears the people who assaulted his family will do worse to him if he returns and he is also fearful about the welfare of his family, mother and siblings. He does not believe the police can protect him as they have yet to arrest anyone over the assault of his wife and children.
The applicant also submitted a Statutory Declaration made [in] October 2014 providing further details of his claims and past experiences in Ghana. The following additional information is contained in the declaration: he lives, and works as [Occupation 1] in Accra, and travels to his village for his chieftaincy responsibilities every fortnight. He travelled to a conference in Australia in July 2014 and decided to stay for a month after for a rest. He received a call from Ghana that people in the village were desperately looking for him with sticks and cutlasses. His father [passed] away [in] December 2012 and three weeks later he was ordered to become the next Chief in accordance with custom as the eldest son of the family. He initially refused to accept it because of his Christian beliefs. [In] January 2013 he was taken by force from his house in Accra at about [time] am, by [men] he knew from his village and was told he had no choice to say no to the Chieftaincy. He went with the men peacefully to the village to convey his decision to refuse it to the elders, but they refused to listen to him and instead locked him in a room for one week and threatened to kill him. [In] January, the elders sacrificed [an animal] and poured blood on his feet, symbolising the initiation of a Chief. He was forced to stay in the village for two weeks before being freed to return to work in Accra on the basis that he would return every fortnight to perform his chiefly duties. He was pressured to accept concubines but he refused. In April –May 2014 he travelled to [Country 1] for business with permission of his elders but was verbally abused when he returned. Because of this he did not tell his elders when he travelled to Australia. When he came to Australia he decided not to return in August for his chiefly duties for the festival and the elders could not find him because he had not told them of his travel. His family told him they became very angry and threatened to kill him. He received an email from a friend [in] September 2014 telling him that they had turned their anger onto his wife and children. They kept them for 6 days and threatened to kill them if they did not tell them of his whereabouts. She told them he was in Australia for business and would return soon. [In] September 2014 people from the village came to Accra to find out if he had returned. When his wife told them he had not they attacked her and physically assaulted his children. His mother and siblings were also present at the time and were also warned that they will be harmed if he does not return. His sister called him to tell him about this and he told her to take his wife to the police to report the assault. According to his wife, she gave the name and description of the person who did it but they have yet to be arrested. His wife was also taken to a hospital for treatment. His family is now living with his sister in [a] suburb of Accra. He is afraid for the welfare of his family because of his refusal to worship and serve pagan gods associated with his duties as Chief and choosing Christian beliefs over pagan customs and rituals.
The applicant submitted the following documents in support of the application:
·Medical Report dated [September] 2014 from [an organisation] relating to [the applicant’s wife], who presented with [a number of injuries] as a result of assaults by a group of people, and she was admitted for [number] days at emergency care.
·General Medical Form from Ghana Police dated [September] 2014, referring [the applicant’s wife] for examination relating to an assault complaint and associated medical officers report.
·Copy of the email dated [September] 2014 from [Mr A] to the applicant informing him his life was in danger and that his wife and children were being kept hostage.
·Emails dated [date and date] September, from [Mr B] and [Mr A], informing the applicant he is being looked for and they will kill him.
·Photos purportedly of the applicant’s wife and children.
·Pages from applicant’s current passport, showing visas and entry stamps for overseas travel to [Country 1] in April 2014 and [Country 2] in July 2014.
·Email dated [March] 2015 from [the applicant’s wife] telling the applicant their lives are very difficult; they are in financial crisis and she is struggling to pay the school fees for the children; she is not too comfortable with those people looking for them
·Email dated [in] May 2015 from [another person] telling the applicant he visited his house recently and it was controlled by the people who are pursuing him and warning him he is still at risk of harm if he returns.
·Report dated [in] November 2014 from [an organisation] relating to [the applicant’s wife] relating to an assault by a group of people, allegedly the second episode.
The applicant attended an interview with the delegate [in] January 2016. The Tribunal has listened to the recording of this interview, a copy of which is held on the Department’s file. During the interview the applicant told the delegate that since making his statement his wife was injured in [a suburb] [in] September 2015 after she had been located by people who were looking for him. He submitted photos of his wife and children, a medical report and two emails. The delegate discussed with the applicant at the interview his previous travel outside Ghana and past passports held. He told the delegate he had a previous passport but he lost it in 2008. He said he has travelled to [Country 1] as mentioned in his application. The delegate put to him a copy of his previous passport showing travel to various countries after 2008, was provided with his [temporary] visa application suggesting that his evidence about this is not truthful. The applicant denied this and said he never provided his previous passport with his [temporary] visa application and was surprised and shocked by this. He added that he travelled to [another country] but he lost his passport in 2008 and does not know if someone else used it to travel to those places.
Documents from the applicant’s [temporary] visa application file, including visa application form, initation to attend the conference in Australia, letter and payslips relating to the applicant’s employment and pages from his previous passport showing previous visas and travel to [several countries] are included in the Department’s file.
The delegate refused the application [in] January 2016, on the basis of not being satisfied the applicant faces a real chance of persecution because of his religion or any other Convention based reason or a real risk he will face significant harm upon return to Ghana.
Before the Tribunal the applicant submitted the following further evidence. A Statutory Declaration by Pastor [name] in support of the applicant’s claims and his character and Christian faith; emails from his brother, [dated] [in] May 2017 and [Mr A] dated [in] June 2017 indicating the applicant is still being sought and his life continues to be in danger; copies of emails previously provided.
Tribunal hearing
A summary of evidence provided by the applicant at hearing follows. He is living in [a suburb in Australia] with the Paster of his church and his wife. He has lived with them since he came to [Australia] in August 2014. He met them coincidently after picking up a flyer about a church at the train station [when] he arrived. The applicant is working at [a] [shop] .
He has no family in Australia. In Ghana he has a wife [and children] aged [ages]. Currently his wife and children are living in the Volta region, some 4-5 hours from Accra. His wife is unemployed and the children are at school. They have been here for the past 2 months and prior to that they were at another place for about 2 months. They are constantly moving because they are being sought by members of his village looking for him. The applicant talks to his wife and children every day. Apart from the two incidents of assault he referred to in his claims, they have not experienced any other incidents of harm, but they are constantly moving to avoid being located. The Tribunal asked the applicant about the email from his [brother]. He said [he] isn’t his real brother, he is a close relative. He did not know the whereabouts of the applicant’s family because they are in hiding. The applicant sends money to his wife regularly, on a fortnightly basis. His mother and sister continue to live in Accra, but also moved to a new address about one year ago. He doesn’t know where his brother is. He has not been in contact with him for over a year now. The applicant believes he is also in fear for his life for the same reasons the applicant’s wife and children are in fear. The applicant’s mother and sister also do not know where the brother is. They are okay but also on edge for the same reasons.
The Tribunal asked the applicant about his education and work history. He said he went to university to study [but] did not complete the [course]. He ceased study in [year] without any qualification. However he was later able to get work in that field working for [a company] from 2006 to 2014. Before that he worked in his [father’s] company. The Tribunal noted that he had not mentioned working at his father’s company in his application. He said he hadn’t realised he needed to go back that far. Regarding past addresses, the applicant said he lived in Accra from birth until he came to Australia. The address provided in the application was the family home he was born in. He later moved, upon marriage, to a separate address nearby but kept using the family home as his permanent address. The second address provided in the application is his father’s village, where he was enstooled, which is some [hours] away from Accra. He was taken here by his father when a child, but since 2013-2014 after he was enstooled, he was visiting there every 2 weeks or less, to complete chiefly duties.
The Tribunal asked the applicant about his travel history prior to coming to Australia. He said he had been to various [countries]. He cannot recall exact dates of travel to these places because he lost his passport around June 2014, just before he came to Australia. When asked the purpose of his travel to these places, he said he was sent there by his father to obtain [goods] for his [father’s] company. He confirmed he travelled to [other countries] in 2012 in the context of his work at his father’s company. The Tribunal noted that he earlier had stated that he worked at [Company 1] from 2006 to 2014 and put to him that his evidence on this appears to be contradictory. He said his father’s company was a family business so he continued to do things for the business even while at [Company 1]. The Tribunal put to him that his various inconsistent responses about his education, work and travel history may lead the Tribunal to have doubts about the truthfulness of his evidence about his background circumstances. In response he reiterated that he worked at [Company 1] as stated. It was [Company 1] that sent him to [Country 1] in 2014, the last place he travelled to before coming to Australia. They also arranged for him to come to the conference in Australia.
Regarding his travel to Australia, the applicant said he came here for a [conference]. He came to [City 2] and attended the conference for [number] days from [date to date] July. His visa allowed up to a three month stay, so after the conference he decided to stay for a few more weeks as leave. He said his ticket to return was about one month after his arrival. The Tribunal asked the applicant why the documents on his [temporary] visa application refer to a conference in [City 1].[1] He said the conference was held in both places, by the time his visa was granted the [City 1] conference had taken place so he came to [City 2] for another conference.[2]
[1] [File number].
[2] [Source deleted].
The Tribunal asked the applicant why he did not depart Australia after that. He said he had not planned to stay, but it dawned on him after he came to Australia what was required of him at the annual August festival in his village and he decided he did not want to go back to that and his Chieftaincy duties. He said this realisation came after he met the Pastor in [Australia] and opened up about his faith and struggles with his traditional role.
The applicant confirmed that he is Christian since birth. His father was also Christian but he abandoned his Christian faith to be Chief.
The Tribunal asked the applicant to describe the process that led to him being chosen for the Chieftaincy. He said he was chosen according to custom, because he is the eldest son of his father, who was the previous chief. He could only answer being of good character when asked if there were other factors that led to his being chosen. When asked the process of his father’s accession to the position, the applicant said he was young then and does not know. The Tribunal asked if there were any other contenders for the position. He said there were not because the monarch had a son, so in that situation there is no one else to choose.
The Tribunal put to the applicant that independent information before it does not support what he has just described as the process for choosing a successor for the Chieftaincy in the Akan tribe. It indicated that the information indicates that generally the Akan tribes follow a matrilineal system and the queen mother selects a number of candidates which are then put to the council to choose. In response the applicant said that there are different subgroups among the Akan and they have different traditions, some of which are matrilineal and some are patrilineal. In his case it is a patrilineal system of succession as he has described. He said he is from the Sefwi subgroup from the western region of Ghana. The Tribunal pointed out that in his application he referred to his village as being in the Eastern Region. He said this was an error because it is in the Western Region.
When he was selected to be the next Chief, he initially protested on the basis of his Christian faith but the elders disagreed with him and insisted he take up the role. He was kept indoors for a period of time and certain rights were performed including the slaughter of animals and blood poured on his feet. He was made to drink the blood of an animal and taken through the village as the new Chief. In this way he was enstooled as Chief [in] January 2013. They wanted him to stay in the village but he managed to convince them to allow him to return to Accra and his work and he agreed to come every fortnight, or as required, to the village to perform chief duties.
He did this until he travelled to [Country 1] in April 2014. He went there to explore the possibility of opening a new branch of his company there. He stayed there until [May] 2014 and returned to Ghana. While he was in [Country 1], there were some incidents in his village and he was needed as Chief for duties, but he was not available and as a result some people became angry, and he was approached with machetes. He was not harmed because the elders defended him.

The Tribunal discussed with the applicant the issue of his ability to travel and reside in other west African countries under the ECOWAS. It explained that if he has such a right to enter and reside then under s36(3) of the Migration Act Australia does not owe him protection. It put to him that his trip to [Country 1] may be relevant for two reasons. Firstly his decision to return to Ghana from there in May 2014 suggests he was not afraid to come back. Secondly, if he has the right to enter and reside in other African countries he may not be eligible for protection under s36(3). In response the applicant said that he had concerns about [Country 1] also because they have similar practices to Ghana (in terms of idol worship). Also he discovered the work he was sent to explore involved illegal [practices] and he was not keen to go further with it. He also mentioned that [another language is spoken in that] country and so he faced a language barrier. All of these are reasons he could not stay in this country. Regarding s36(3) the applicant told the Tribunal that Ghana is in fact more peaceful than many of the other countries in the region so more people come to Ghana than Ghanaians leaving for their countries. He also does not believe he has a right to enter and reside unless he has been sent for work by a company. His company no longer exists so he has no employer who could send him anywhere for work.
The Tribunal asked the applicant if he experienced past harm in Ghana. He said he did not experience physical harm but some of the practices he had to endure including drinking blood of animals made him sick to the point of having to visit hospital. Since he has been in Australia he has felt so much better in terms of health. While he was never physically harmed in his role as Chief, he was threatened to take on the role in the first place and the threats only ended when he agreed to be Chief. When he returned from [Country 1], he was pursued by people with machetes and was only not harmed because some elders defended him.
Since he has been in Australia the elders of the village are angry he has not returned and have been pursuing his family. They consider his absence to be a sign of disrespect. Also some members of the royal family are concerned that they will lose the throne to another family so they are angry with him for this reason. When asked why someone else has not been enstooled since then, he said they cannot enstool anyone until he dies.
The Tribunal asked about the claims of harm against his wife and noted that in his written claims he refers to a police report where she has named and described the assailants however no such document has been submitted. He said he provided the documents he has. Regarding the second claimed incident he referred to at the Department interview, it asked him to describe this incident. He said it happened just before the interview. His wife was located and they asked her about his whereabouts and molested her as a way to make him return. He said this occurred around September 2015. He indicated that he provided a report she made about the incident to the delegate. The Tribunal confirmed with the applicant the timing of the incident. He said it was not long before the interview, maybe a few months. The Tribunal asked the applicant why then the report he submitted has a date of November 2014? He said he may have been confused about the date but the incident did occur. The Tribunal put to him that it may have doubts about this given this discrepancy and this may also reflect poorly on his credibility. It also put to him that it has concerns, if his family was really at risk of harm because of his absence, that he would remain away for 3 years and continue to place them at risk. The applicant made so specific response to this.
The Tribunal put to the applicant that it has now been three years since he left Ghana and it has difficulty accepting that they would not have found someone else to be the Chief by now. The applicant said he suspects strongly that there is a penalty awaiting him if he returns to Ghana.
The Tribunal returned to the issue of the independent information which does not support his claims of being forcibly enstooled to the Chieftaincy. He said the information the Tribunal is referring to may relate to the Asante subgroup of the Akans who are the largest group. There are variations applicable to other groups.
The Tribunal put to the applicant that independent information also indicates that forced enstoolment is not a common occurrence and while a person may suffer family and social pressure and be socially isolated and forced to leave the village there is no evidence of mistreatment or harm for this reason. In response the applicant said that not everything that happens in Ghana is reported and the country information may not reveal things that do happen there, such as ritual human sacrifices. He is aware of practises that occur which are not reported on, and on this basis, he argues that the Tribunal should not rely on the absence of country information about this. The applicant reiterates he has claimed he is a traditional ruler but he has abdicated his role because of his Christian faith and he cannot now go back to the role. His wife and children are now being subjected to harm because of his actions and it will be worse for him upon return.
The Tribunal asked the applicant why he cannot return to Accra which is [a number of] hours away from his village, and be safe there. He said Ghana is not such a large place and they will find him in Accra. The chieftaincy involved taking an oath and there are implications for him because of the oath he has taken. The applicant stated the person he is specifically afraid of his father’s brother. He said a lot of things are done in secret such as sacrifices. He is aware of things like ritual killings. He is afraid he could be killed if he returns.
The representative made oral submissions addressing the following three matters. Firstly the applicant’s fear of return commenced only after he decided not to return to Ghana after coming here. He has only not returned now because of the fear of repercussions of his extended absence. Regarding the independent information referred to he submits that, as stated by the applicant, many things that go on in Ghana, including extrajudicial killings, go unreported. Also regarding the matrilineal and patrilineal traditions, most of the research available publically relates to the Asante subgroup which is not the group the applicant belongs to. He requested 2 weeks to provide submissions on issues arising at the hearing.
On 18 September 2017 the Tribunal received a written submission from the applicant’s representative addressing the issue of chieftaincy and patrilineal inheritance in Ghana. The submission discusses the concept of inheritance in the Ghanaian context, pointing out that the term ordinarily refers to property, and that the two main forms of customary inheritance in Ghana is matrilineal and patrilineal inheritance. The Akan, comprising of several tribal and kingship groups in southern Ghana have a matrilineal inheritance custom. However, the submission argues that not all Akan groups are matrilineal, there are some patrilineal enclaves within the Akan group, and a reference is cited from a Master of Philosophy thesis, discussing Chieftaincy disputes in Akan Akuapem area, mentioning several tribes who inherit through paternal lines. This source also states that “the son of a chief, in addition to all male born children of the chief’s brothers, can succeed to the throne of a vacant stool”, and that first sons among all the past chiefs siblings are first considered in choosing a succeeding chief. The submission argues that while these comments are in reference to the Akan Akuapem, they support that among the Akan there are patrilineal groups. Further the representative states, even among matrilineal groups adherence to matrilineal inheritance customs does not necessarily apply to the selection of chiefs. The Tribunal notes the quote cited by the representative in support of this claim, stating “ formal rules of descent and inheritance were frequently set aside in accordance with the principle that ‘all succession is a question of election by relatives; not of inherent right’”.
The representative submits the applicant’s claim is that he inherited the position of chief from his father and was enstooled accordingly. It is submitted that the above referenced reports supports the applicant’s claims by confirming that patrilineal inheritance does exist in Akan areas in Ghana and even in matrilineal areas inheritance does not extend to selection of chiefs. In addition it is submitted the applicant’s family migrated from [a district] in the eastern region of Ghana to settle in [Village 1] in the Western region to work [and] in doing so brought their [culture] and traditions with them, which explains why the chieftaincy follows patrilineal traditions rather than matrilineal usually practised by other Akans.
Independent information
Chieftaincy Issues
The role of chief in Ghana usually involves being the head of a small village. Disputes over chieftaincy involve rival groups vying to install their preferred candidate as chief. A Brandeis University study in 2009 reported that despite Ghana’s relative stability compared to other countries in the region, there had been several outbreaks of ethnic and chieftaincy conflicts over the years. [3]
[3] Coexistence International at Brandeis University 2009, Country Studies Series: Ghana, February, – Accessed 8 April 2010 – Attachment 2
The UK Home Office’s Operational Guidance Note: Ghana, November 2013[4] states in relation to Chieftain disputes:
3.10.2 Treatment. Despite being a multiethnic country, there is relatively little discrimination based solely on ethnicity in Ghana. However, local disputes over land use and chieftaincy sometimes lead to ethnically tinged violence, and the political exploitation of ethnicity has exacerbated some conflicts. This is particularly true in areas where tenant farmers occupy and develop land whose owners are from another ethnic group. It is considered a major honour and duty to become a Chief as the individual is embodying the well-being and reputation of the group. The "consequences" of refusing or misbehaving, then, increase with the greater level of chieftainship concerned.[5]
3.10.3 Chieftaincy disputes, which frequently resulted from a lack of clear succession, competing claims over lands and other natural resources, and internal rivalries and feuds, continued to result in deaths, injuries, and destruction of property.[6]
3.10.4 In 1 July 2012 correspondence with the Immigration and Refugee board of Canada Research Directorate, an Associate Professor of anthropology at York University in Toronto who has conducted field research in Ghana indicated that a person refusing/turning-down a chieftaincy position may be socially ostracised (they are putting their kin group and community at disadvantage and risk, and may also be costing them economic benefits, so life thereafter for that person may be quite unpleasant), perhaps driven away. [7]
3.10.5 In a statement the Chieftaincy Ministry said government expects all those engaged in chieftaincy disputes to follow the laid down procedures for settling such disputes. Chieftaincy Minister Dr. Henry Seidu Daannaa told Joy News those in dispute should go to court and not take the law into their own hands. 'As a matter of law government cannot go in and say this person is a chief or this person is not. What we can do is to facilitate and ensure that this structure works. And so we expect that all royal stakeholders in the chieftaincy should go by the structures and those who are not happy with the decisions of these structures can appeal to the courts. 'They cannot operate outside the law,' he warned.[8]
·3.10.6 The Ghanaian Government has warned it would not tolerate any breach of public peace by factions in chieftaincy disputes around the country. In June 2013 another chieftaincy clash in Teshie in Accra, claimed one life whilst several people sustained injuries.
[4] United Kingdom: Home Office, Operational Guidance Note: Ghana, November 2013, Ghana OGN v 12.0, available at: [accessed 31 August 2017]
[5] Freedom House, Countries at Crossroads 2012; Ghana, 20 September 2012, US State Department, Country Reports on Human Rights Practices 2012: Ghana, Section 6, 19 April 2013, The most recent US State Department Country Reports on Human Rights Practices 2016: Ghana states, at Section 6, “ Unlike in prior years, there were no reports of ritual killings.” The report otherwise repeats the above advice in respect of chieftaincy disputes: Immigration and Refugee Board of Canada, Ghana: Consequences of refusing a fetish priest or chieftaincy position, and whether there is state protection available, 16 August 2012, Modern Ghana, Gov't to crack down on factions in chieftaincy disputes, 22 June 2013 >
The most recent US State Department Country Reports on Human Rights Practices 2016 states “ Unlike in prior years, there were no reports of ritual killings.” The report otherwise repeats the above advice (see 3.10.3 above) in respect of chieftaincy disputes.[9]
[9]US State Department Country Reports on Human Rights Practices 2016: Ghana, Section 6 >
The Tribunal has considered the information contained in the research response prepared for the Canadian Immigration and Refugee Board of Canada in July 2012,[10] referred to above (3.10.4). This information specifically discusses processes for choosing chiefs and consequences of refusing a chieftaincy position, and indicates that there is no practice of punishing persons for refusing or running away from the offer of a position. The following extracts are relevant :
[10] Canada: Immigration and Refugee Board of Canada, Ghana: Consequences of refusing a fetish priest or chieftancy position, and whether there is state protection available, 16 August 2012, GHA104154.E, available at: the personal level, a person refusing/turning-down such a position … may be socially ostracised (they are putting their kin group and community at disadvantage and risk, and may also be costing them economic benefits, so life thereafter for that person may be quite unpleasant), perhaps driven away….
… Succession for [the] head of clan is by election by the elders of that clan who choose among several candidates on the basis [of] which one can bring the most resources to the stool (symbol of office).
That is why, today, the more important and powerful offices are filled by educated and wealthy persons, including successful lawyers and other professionals, senior civil servants, and business owners.
The holding of office is time consuming, and certainly takes resources, as an elder or chief must provide refreshments for visitors and subordinate office holders, and must spend long hours hearing sometimes complicated cases of dispute.
Therefore, there is a resistance by young persons, especially those who are still studying and those have not reached what they consider the pinnacle of their professional career, to accept an offered office, and that reluctance is greater for lower positions in the overall hierarchy.
Meanwhile, the elders seeking an office holder want the most highly educated, and potentially wealthy and powerful candidates, in their own right, to be the office holders.
Most other excuses for a person refusing an offered office, such as being Christian and not wanting to participate in traditional ancestor homage and recognition of local deities, are less important in the overall scheme of things. The people of Southern Ghana are notable syncretists, being able to accommodate many, often incompatible (in our eyes), religious beliefs….
The usual method for a person who does not want to accept an offered office is to travel so as to avoid the possibility of being offered the position. The elders are quite aware of this method, and incorporate it into their deliberations. [In] their minds, it is preferable that not many contenders, who will have different groups of supporters within the clan, are around to mess up the replacement process (e.g., enstoolment). To maintain their pride and face, the persons running away will exaggerate the danger to themselves of refusing a proffered office. ...
There is no practice of punishing persons for running away before being offered a position as chief or elder, including female positions such as Queen Mother. If the chosen person is not bright enough to run away, and wants to refuse office, the usual practice is for him or her to offer a sheep to sacrifice to pacify the annoyed ancestors, and that is the end of it. There is no need for state protection because there is no punishment. The disappointed elders may express their irritation, but it happens so often, they usually sigh and are resigned to the fact.
Specific information is also provided in the same research response of the procedures for selection of chief among the Akan, referring to prescriptive and elective elements:
The selection of a chief (ohene, pl. ahene) among the Akan combines both prescriptive and elective elements. On the one hand, there is a group of people known as the royals who are all, given the certain restrictions of sex and age, genealogically qualified to occupy the chiefly office vested in the ruling lineage of a community. On the other hand, a candidate has to be suitable, not only in terms of genealogy, but also in terms of character, intelligence, health, physical fitness, and so on. In addition to these personal qualifications, a candidate has to have support among the so-called kingmakers of the community (i.e., the divisional chiefs or headmen kin groups). Conflicts in a selection process mostly arise from competition between two or several candidates, but in some cases, which in my experience are much more rare, a person, who might be the most (or only) eligible candidate for the office, refuses the candidacy and is pressured by his community to accept it. Some of the so-called born-again Christians reject chieftaincy because of the ritual duties involved (i.e., offering sacrifices to the ancestors and deities). Such cases have been around since the early days of Christian conversion (19th and early 20th centuries). More recently, I have talked with immigrant men who refuse to visit their home towns or villages in Ghana, because allegedly they would be "kidnapped" and installed as chiefs against their own will. In these cases, the chiefly title is seen as something that would restrict their movement. (researcher 4 July 2012)
In a detailed research response commissioned by the RRT in 2009[11], it was noted that available information indicates that Asante and Akan Chieftaincy is based on matrilineal succession. An individual’s right to assume the Chieftaincy is thus based on their mother’s royal lineage. Reports indicate that under this system there can be many possible candidates for succession to the Chieftaincy. Sources consulted report that the Asante and Akan people undertake a formal process to select a new Chief. Reports state that the Queen Mother is responsible for selecting a candidate for the Chieftaincy. The Queen Mother does this through a process of consultation with members of the royal family and elders. In choosing a candidate for the Chieftaincy the Queen Mother must consider royal lineage as well as the personal characteristics of potential candidates. The Queen Mother is allowed to choose three candidates for the consideration of the traditional council before the council itself can choose an individual for the Chieftaincy. Some reports state that candidates for the Chieftaincy are then presented at a public gathering so citizens can express their approval or disapproval. It should be noted that according to a 1976 journal article on the Asante Chieftaincy formal matrilineal lines of succession are not always rigorously observed and that “rules of accession differ from stool to stool throughout Ashanti.”[12]
[11] Ghana – GHA35054 – Chieftaincy – Succession – Disputes – Asante – Seventh-day Adventists in Ghana – Traditional Religion – State Protection – Religious Freedom, 3 August 2009
[12] Stoeltje, B.J. 1997, ‘Asante Queen Mothers’, Annals of the New York Academy of Sciences, , vol. 810, June, pp. 41& 53; The African Executive, 16 November type="1">
The Tribunal also considered a paper, Social responsibility in the Christianised Akan Ethnic Culture of Ghana, by Joseph Quayesi-Amake, which discusses the socio-cultural implications of and tensions between being a Christian on the one hand and a Ghanaian ethnic chief on the other.[13]
[13] AND REASONS
Nationality
On the basis of the evidence of the applicant’s passport the Tribunal finds that he is a citizen of Ghana and Ghana is his country of nationality for the purposes of this assessment of protection obligations.
Consideration of applicant’s claims
When assessing claims made by an applicant the Tribunal needs to make findings of fact in relation to those claims. This usually involves an assessment of credibility of the applicant. When doing so the Tribunal is mindful of the difficulties faced by refugee applicants, including issues relating to use of interpreters, nervousness and anxiety in the environment of interviews and hearings, and memory and recollection issues resulting from the lapse of time or other reasons. The benefit of the doubt should be given to an applicant who is generally credible but unable to substantiate all of his or her claims. The Tribunal is mindful that if it makes an adverse finding in relation to a material claim made by the applicant but is unable to make that finding with confidence it must proceed to assess the claim on the basis that it might possibly be true. (See MIMA v Rajalingam (1993) FCR 220) However the Tribunal is not required to accept uncritically any or all of the allegations made by an applicant. Further, the Tribunal is not required to have rebutting evidence available to it before it can find that a particular factual assertion by an applicant has not been made out. (see Selvadurai v MIEA& Anor (1994) 34 ALD 347 at 348).
In assessing the applicant’s claims, the Tribunal has taken into account the information in the Department’s files before it, including his application for the Protection visa, the documents and evidence he provided to support his claims, his evidence to the delegate at interview and written and oral evidence he gave when he appeared before the Tribunal. It has also had regard to independent information referred to in the delegate’s decision and above regarding relevant matters in Ghana and the information provided in the applicant’s submissions to the Tribunal.
The applicant has advanced the following claims in his application for protection. He is chief of his village and fears harm upon return to Ghana because he abandoned his position when he failed to return from Australia. He was forcibly enstooled as chief upon the death of his father who was the previous chief. He claims he is a Christian and is opposed to the pagan rituals and traditions and he does not want to return to his chief duties. He claims since his failure to return to Ghana from Australia, his wife and children have been threatened and harmed as a means to pressure his return. He claims his wife was assaulted by members of village on two separate occasions. He claims his wife and children have had to move several times because of this and continue to be in hiding. He fears severe punishment awaits him by members of his village community if he returns to Ghana.
For the reasons explained below, the Tribunal does not accept the applicant is telling the truth about his circumstances in Ghana and the reasons he left the country. The Tribunal has concerns about the credibility of his claims and evidence relating to his circumstances and past experiences in Ghana and the reasons he left the country. It has doubts about whether he was working as [Occupation 1] in Ghana and travelled to Australia to attend a [conference]. It does not accept that he was enstooled as chief of his village in 2012, forcibly or otherwise. Consequently it also does not accept that his wife and children have been threatened or harmed because of his failure to return to Ghana for this reason. It does not accept that he will face harm upon return to Ghana from his father’s brother, or any members of the village, or any other person.
The Tribunal does not find the applicant’s claims to be credible. His evidence regarding his background circumstances has been inconsistent and at times evasive, causing the Tribunal to have doubts about his true circumstances and motivations. For example, he indicated in his application form that he held tertiary qualifications and was employed as [Occupation 1] from 2006-2014, and only mentioned one past overseas trip to [Country 1] in 2014. At the interview before the delegate, he was asked about his previous passport, copy of which was provided with his [temporary] visa application, which indicated travel to various countries. In response to the delegate he claimed he lost his passport in 2008 and denied having travelled to any of these countries. However, before the Tribunal he gave different evidence about his education and travel history. He told the Tribunal he has not completed any qualification at university and that he worked with his father in his [company] and, in that context, travelled overseas to various [countries]. He confirmed that he travelled to [different countries] in 2012, in the context of his work for his father’s company. He told the Tribunal that he couldn’t recall the exact dates of his travel to these places because he lost his passport around June 2014, before coming to Australia. When the Tribunal put to him for comment the inconsistencies in his evidence about his previous passport and travel, he explained that he was confused about the questions and was focussed on his most recent trip before coming to Australia.
The Tribunal has considered this response, and the evidence before it, however it is not convinced it adequately explains the inconsistent and contradictory evidence. It notes that his current passport was issued [in] 2014 and indicates his travel to [Country 1] that month, contradicting his claim to have lost his previous passport in June 2014. The Tribunal finds the evidence about his education background and admission that he has no tertiary qualification as claimed in his application inconsistent with his claimed profession as [Occupation 1]. It notes that he claims to have travelled to Australia, supported by his company, to attend [the] Conference in [City 1] from [date to date] July 2014, however his visa was not granted until [July] 2014 and he arrived in [City 2] [in] July 2014. He explained that because of the delay in processing of his visa, he missed the [City 1] conference, and instead attended a different conference in [City 2]. While this explanation is consistent with the evidence, the inconsistencies and omissions in his evidence about his background circumstances cause the Tribunal to have doubts about his credibility, whether he worked as [Occupation 1] in Ghana at all and his true motivation to travel to Australia. The Tribunal considers it is more likely that he did not, and in fact came here in 2014 with the intention of remaining and working for income. On his own evidence, the company he worked for no longer exists.
Claims relating to his enstoolment as chief of his village
The above adverse credibility assessment also influences the Tribunal’s assessment of his claims relating to his position as chief of his village and that he was enstooled against his will in January 2012. The Tribunal found his evidence about this vague and lacking in convincing detail, and inconsistent with independent information before the Tribunal about processes for selection and enstoolment of chiefs amongst the Akan ethnic group. His evidence was that he was chosen to be chief solely on the basis of his position as eldest son of his father, who was the previous chief and he was the only contender for the position for that reason. He indicated he initially protested, on the basis of his Christian faith but he was taken by force and made to take up the role.
The Tribunal found the applicant’s responses when questioned about why and how he was selected as chief were vague and lacking in convincing detail. The Tribunal also raised with him that his claims did not appear to be consistent with independent information about succession principles and the selection process for Chieftaincy among the Akan. This information indicates succession is generally based on a matrilineal system, and the formal process is that the Queen Mother selects a number of candidates for the consideration of the traditional council of elders and royal lineage as well as personal characteristics are taken into account in selecting candidates.[14] When this was put to him at the hearing the applicant responded that there are different subgroups among the Akan and variations in the principles and procedures amongst them and while some groups have matrilineal succession, others have patrilineal succession. He did not give any more detailed information or explanation about his tribe and its particular traditions. Following the hearing, his representative provided a submission in support of his contention that there are patrilineal groups among the Akan, referring specifically to a source of information referring to patrilineal tribes in the Akan Akuapem area where the son of a chief, in addition to all male born children of the chief’s brothers, can succeed to the throne of a vacant stool and that first sons among all the past chiefs siblings are first considered in choosing a succeeding chief. No specific claim or evidence linking the applicant to this tribe was provided in the submission.
[14] See, RRT Research Response GHA35054, 3 August 2009, citing Stoeltje, B.J. 1997, ‘Asante Queen Mothers’, Annals of the New York Academy of Sciences, , vol. 810, June, pp. 41& 53; Amankona, F.D. 2005 ‘The Chieftaincy Institution-Lessons from Our Ancestors and Traditions’, The African Executive, 16 November >
The Tribunal has carefully considered the applicant’s responses and supporting material provided, as well as the other independent information it has before it, referred to above. Acknowledging the limitations of relying on country information written at a level of generality, it is prepared to accept the applicant’s submission that there may be variations of traditions among subgroups of the Akan, including that some groups may follow patrilineal lines. On this basis the Tribunal accepts that most but not all Akan tribes follow matrilineal traditions. However, a common element from all the sources (including the source referred to by the applicant) is that selection of successor for the position of chief occurs by way of an election among candidates, even if there may be differences among groups as to who are eligible for selection and how they are selected and/or elected. The Tribunal notes that even the source cited by the applicant’s representative concedes that “all succession [is ultimately] a question of election by relatives; not of inherent right’.” This is not consistent with the applicant’s claim to have been appointed as chief solely on the basis of being the eldest son of the previous chief.
In addition not being supported by independent information, the Tribunal found the lack of spontaneous or detailed response from the applicant at hearing about his specific tribe and traditions also diminished the credibility of his claim.
He has claimed that his wife and children have been threatened and suffered physical harm from village members looking for him and seeking his return. The Tribunal does not accept this claim. Limited credible evidence has been submitted in support of these claims. He claimed his wife made a complaint to police, naming the assailants though no action against them was taken. However, there is no evidence of a police report of the incident in which she has named any specific individual. The Tribunal gives limited weight to the documents he did provide, given this inconsistency between his written and oral claims and documents provided and adverse assessment of his credibility generally. The Tribunal has considered but gives little weight to the email correspondence between the applicant and [Mr A] and [Mr B], and later emails from [the applicant’s brother] and [Mr A] dated May and June 2017 on the basis of its overall adverse credibility assessment of the applicant. It considers these to be self serving and unverifiable. It also observes that the document provided to the delegate at the interview about a purported subsequent assault in September 2015, is dated November 2014, reinforcing the Tribunal’s concerns about the reliability and credibility of his claims.
Finally, the Tribunal finds it difficult to believe and accept that, if his wife and children were genuinely at risk of serious harm because of his absence from the country, he would remain away.
The Tribunal accepts the applicant’s claim that he is a Christian, from a Christian family, taking into consideration the support letter from [the Pastor] as well as country information about the size and extent of the Christian population in Ghana. Although the letter also makes reference to the Pastor’s knowledge of the applicant’s chieftaincy enstoolment and circumstances of his wife and children, the Tribunal considers this is based on information given by the applicant himself and therefore, having regard to its adverse credibility assessment and rejection of these claims above, the Tribunal does not give weight to the Pastor’s evidence on this matter. It does accept however, as plausible and possible that he has joined and participates in a church community while in Australia, and that this is consistent with him being of the Christian faith in Ghana.
Conclusions
For all of the above reasons, on the evidence before it, the Tribunal does not accept that the applicant was enstooled as the chief of his village, forcibly or otherwise. As a consequence of this conclusion, it also does not accept that his wife and children have been threatened or assaulted because of his failure to return to Ghana to perform duties as chief. It does not accept that his wife and children are living in hiding for this reason.
There is no evidence before the Tribunal to indicate that the applicant will face a real chance of serious harm for reasons of his Christian faith or as a result of being from a Christian family. The Tribunal observes that Ghana has a significant Christian population and Christianity has increasingly shifted from the religious periphery to assume an important role in Ghanaians’ lives.[15] Information indicates that Christianity would not prevent a person accepting chieftancy, although it may be offered as an excuse for refusing an offer of chieftancy.[16]
[15] See for example, Social responsibility in the Christianised Akan Ethnic Culture of Ghana, by Joseph Quayesi-Amake, fn 13 above.
[16] Canada: Immigration and Refugee Board of Canada, Ghana: Consequences of refusing a fetish priest or chieftancy position, and whether there is state protection available, 16 August 2012, GHA104154.E, available at: >
Despite rejecting his claims that he was the chief of his village, the Tribunal has nevertheless considered whether, accepting he is Christian and for that reason opposed to undertaking the duties of a chief, he is at risk of being forcibly enstooled upon return to Ghana. The independent information before the Tribunal indicates that forced enstoolment is not a common occurrence in Ghana. At most a person who refuses the chieftaincy in Ghana may suffer family and social pressure and may be socially isolated and forced to leave their village. Given that the applicant lived most of his life in Accra, far from his village, this would have no adverse impact on him. Available information suggests that there no further serious punishments for refusing the chieftaincy in Ghana including being physically forced to assume the chieftaincy.[17]
[17] Ibid.
Having regard to these findings, and considering the applicant’s claims individually and cumulatively, the Tribunal is not satisfied that the applicant faces a real chance of persecution for reasons of abandoning a position of chief of his village; his ethnicity; membership of the particular social group; his Christian religion or any other reason.
For the reasons given above, the Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under the Refugees Convention. Therefore the applicant does not satisfy the criterion set out in s.36(2)(a).
Complementary Protection criteria
The Tribunal has also considered whether there are substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to Ghana, there is a real risk that he will suffer significant harm as defined in s36(2A) of the Act.
Having regard to the evidence and claims before it, and considering the applicant’s circumstances singularly and on a cumulative basis, and the Tribunal’s reasons, above, for the absence of a real chance of serious harm, the Tribunal is also not satisfied there is a substantial basis to believe there is a real risk the applicant will be arbitrarily deprived of his life; or the death penalty will be carried out on him; or that he will be subjected to torture; or to cruel or inhuman treatment or punishment; or to degrading treatment or punishment if he is returned to Ghana.
The Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s.36(2)(aa).
There is no suggestion that the applicant satisfies s.36(2) on the basis of being a member of the same family unit as a person who satisfies s.36(2)(a) or (aa) and who holds a protection visa. Accordingly, the applicant does not satisfy the criterion in s.36(2).
DECISION
The Tribunal affirms the decision not to grant the applicant a Protection visa.
Meena Sripathy
Member

ATTACHMENT - RELEVANT LAW
The criteria for a protection visa are set out in s.36 of the Act and Schedule 2 to the Migration Regulations 1994 (the Regulations). An applicant for the visa must meet one of the alternative criteria in s.36(2)(a), (aa), (b), or (c). That is, the applicant is either a person in respect of whom Australia has protection obligations under the ‘refugee’ criterion, or on other ‘complementary protection’ grounds, or is a member of the same family unit as such a person and that person holds a protection visa of the same class.
Refugee criterion
Section 36(2)(a) provides that a criterion for a protection visa is that the applicant for the visa is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations under the 1951 Convention relating to the Status of Refugees as amended by the 1967 Protocol relating to the Status of Refugees (together, the Refugees Convention, or the Convention).
Australia is a party to the Refugees Convention and generally speaking, has protection obligations in respect of people who are refugees as defined in Article 1 of the Convention. Article 1A(2) relevantly defines a refugee as any person who:
owing to well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, is outside the country of his nationality and is unable or, owing to such fear, is unwilling to avail himself of the protection of that country; or who, not having a nationality and being outside the country of his former habitual residence, is unable or, owing to such fear, is unwilling to return to it.
Sections 91R and 91S of the Act qualify some aspects of Article 1A(2) for the purposes of the application of the Act and the Regulations to a particular person.

There are four key elements to the Convention definition. First, an applicant must be outside his or her country.
Second, an applicant must fear persecution. Under s.91R(1) of the Act persecution must involve ‘serious harm’ to the applicant (s.91R(1)(b)), and systematic and discriminatory conduct (s.91R(1)(c)). Examples of ‘serious harm’ are set out in s.91R(2) of the Act. The High Court has explained that persecution may be directed against a person as an individual or as a member of a group. The persecution must have an official quality, in the sense that it is official, or officially tolerated or uncontrollable by the authorities of the country of nationality. However, the threat of harm need not be the product of government policy; it may be enough that the government has failed or is unable to protect the applicant from persecution.
Further, persecution implies an element of motivation on the part of those who persecute for the infliction of harm. People are persecuted for something perceived about them or attributed to them by their persecutors.
Third, the persecution which the applicant fears must be for one or more of the reasons enumerated in the Convention definition - race, religion, nationality, membership of a particular social group or political opinion. The phrase ‘for reasons of’ serves to identify the motivation for the infliction of the persecution. The persecution feared need not be solely attributable to a Convention reason. However, persecution for multiple motivations will not satisfy the relevant test unless a Convention reason or reasons constitute at least the essential and significant motivation for the persecution feared: s.91R(1)(a) of the Act.
Fourth, an applicant’s fear of persecution for a Convention reason must be a ‘well-founded’ fear. This adds an objective requirement to the requirement that an applicant must in fact hold such a fear. A person has a ‘well-founded fear’ of persecution under the Convention if they have genuine fear founded upon a ‘real chance’ of being persecuted for a Convention stipulated reason. A ‘real chance’ is one that is not remote or insubstantial or a far-fetched possibility. A person can have a well-founded fear of persecution even though the possibility of the persecution occurring is well below 50 per cent.
In addition, an applicant must be unable, or unwilling because of his or her fear, to avail himself or herself of the protection of his or her country or countries of nationality or, if stateless, unable, or unwilling because of his or her fear, to return to his or her country of former habitual residence. The expression ‘the protection of that country’ in the second limb of Article 1A(2) is concerned with external or diplomatic protection extended to citizens abroad. Internal protection is nevertheless relevant to the first limb of the definition, in particular to whether a fear is well-founded and whether the conduct giving rise to the fear is persecution.
Whether an applicant is a person in respect of whom Australia has protection obligations is to be assessed upon the facts as they exist when the decision is made and requires a consideration of the matter in relation to the reasonably foreseeable future.
Complementary protection criterion
If a person is found not to meet the refugee criterion in s.36(2)(a), he or she may nevertheless meet the criteria for the grant of a protection visa if he or she is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to a receiving country, there is a real risk that he or she will suffer significant harm: s.36(2)(aa) (‘the complementary protection criterion’).
‘Significant harm’ for these purposes is exhaustively defined in s.36(2A): s.5(1). A person will suffer significant harm if he or she will be arbitrarily deprived of their life; or the death penalty will be carried out on the person; or the person will be subjected to torture; or to cruel or inhuman treatment or punishment; or to degrading treatment or punishment. ‘Cruel or inhuman treatment or punishment’, ‘degrading treatment or punishment’, and ‘torture’, are further defined in s.5(1) of the Act.
There are certain circumstances in which there is taken not to be a real risk that an applicant will suffer significant harm in a country. These arise where it would be reasonable for the applicant to relocate to an area of the country where there would not be a real risk that the applicant will suffer significant harm; where the applicant could obtain, from an authority of the country, protection such that there would not be a real risk that the applicant will suffer significant harm; or where the real risk is one faced by the population of the country generally and is not faced by the applicant personally: s.36(2B) of the Act.
Section 499 Ministerial Direction
In accordance with Ministerial Direction No.56, made under s.499 of the Act, the Tribunal is required to take account of policy guidelines prepared by the Department of Immigration –PAM3 Refugee and humanitarian - Complementary Protection Guidelines and PAM3 Refugee and humanitarian - Refugee Law Guidelines – and any country information assessment prepared by the Department of Foreign Affairs and Trade expressly for protection status determination purposes, to the extent that they are relevant to the decision under consideration.

and also Canada: Immigration and Refugee Board of Canada, Ghana: Consequences of refusing a fetish priest or chieftancy position, and whether there is state protection available, 16 August 2012, GHA104154.E, available at:

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1601521 (Refugee) [2017] AATA 2140

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Minister for Immigration & Multicultural Affairs v Rajalingam [1999] FCA 719

[2017] AATA 2140

24 October 2017

Key Legal Topics

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Immigration

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Judicial Review

Procedural Fairness

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