1610608 (Refugee)
[2019] AATA 4599
•17 October 2019
1610608 (Refugee) [2019] AATA 4599 (17 October 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER: 1610608
COUNTRY OF REFERENCE: Indonesia
MEMBER:Sheridan Lee
DATE:17 October 2019
PLACE OF DECISION: Melbourne
DECISION:The Tribunal affirms the decision not to grant the applicant a protection visa.
Statement made on 17 October 2019 at 10:14am
CATCHWORDS
REFUGEE – protection visa – Indonesia – partner violence – attacks and threats by boyfriend – credibility – inconsistent evidence – unlawful residence in Australia – delay in applying for protection – no real risk of significant harm – decision under review affirmedLEGISLATION
Migration Act 1958 (Cth), s 36, 65
Migration Regulations 1994 (Cth), Schedule 2CASE
Minister for Immigration and Ethnic Affairs and McIllhatton v Guo Wei Rong and Pam Run Juan (1996) 40 ALD 445
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 and Border Protection on 20 July 2015 to refuse to grant the applicant a protection visa under s.65 of the Migration Act 1958 (the Act).
The applicant is a [age] year old Indonesian woman of Chinese heritage and Christian faith. She applied for the visa on 21 July 2015. The delegate refused to grant the visa on the basis that effective state protection would be available to the applicant in Indonesia.
The Tribunal viewed a copy of the applicant’s Indonesian passport and I accept that the applicant is a citizen of Indonesia and will assess her claims against Indonesia as the country of reference for the purposes of s.5H(1)(a) and receiving country for Complementary Protection purposes.
CRITERIA FOR A PROTECTION VISA
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, he or she 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.
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 because the person is a refugee.
A person is a refugee if, in the case of a person who has a nationality, they are outside the country of their nationality and, owing to a well-founded fear of persecution, are unable or unwilling to avail themselves of the protection of that country: s.5H(1)(a). In the case of a person without a nationality, they are a refugee if they are outside the country of their former habitual residence and, owing to a well-founded fear of persecution, are unable or unwilling to return to that country: s.5H(1)(b).
Under s.5J(1), a person has a well-founded fear of persecution if they fear being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, there is a real chance they would be persecuted for one or more of those reasons, and the real chance of persecution relates to all areas of the relevant country. Additional requirements relating to a ‘well-founded fear of persecution’ and circumstances in which a person will be taken not to have such a fear are set out in ss.5J(2)-(6) and ss.5K-LA, which are extracted in the attachment to this decision.
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 the 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 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’). The meaning of significant harm, and the circumstances in which a person will be taken not to face a real risk of significant harm, are set out in ss.36(2A) and (2B), which are extracted in the attachment to this decision.
Mandatory considerations
In accordance with Ministerial Direction No.84, made under s.499 of the Act, I have taken account of the ‘Refugee Law Guidelines’ and ‘Complementary Protection Guidelines’ prepared by the Department of Home Affairs, and country information assessments 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.
CONSIDERATION OF CLAIMS AND EVIDENCE
Claims for protection
The applicant was born in Surabaya, Indonesia. She first arrived in Australia [in] June 2011 on a [temporary] visa. The [visa] ceased [in] July 2011 and the applicant remained in Australia unlawfully from that time.
On 20 July 2015, the applicant applied for a protection visa on the basis that she fears harm from her ex-boyfriend, [Mr A], if returned to Indonesia. The application for protection form outlined that:
·the applicant got to know [Mr A] in 1988. He is a bad and violent person.
·[Mr A] did not want to marry the applicant and had many girlfriends; however, he would not allow the applicant to see other people.
·in 1995, the applicant advised [Mr A] that she wished to marry another man. He put a knife to her father’s throat and threatened to kill him if the applicant married the other man. That night he tortured the applicant and the next day she ran away. [Mr A] could not find her.
·the applicant’s father died in a car accident one month later. The applicant suspected that [Mr A] was behind the accident as he was friends with the driver. The applicant reported this to the police, but the police said there was no evidence.
·[Mr A]’s brother is a police officer. The applicant does not believe that the Indonesian authorities could protect her.
·the applicant felt she had to treat [Mr A] as a king. He would threaten to kill her if she ran away. The applicant fears that [Mr A] will kill her if he finds her.
·the applicant tried to move to other places many times, but [Mr A] would always find her. She believes his brother would assist him to find her.
The application form also outlined that the applicant lived in Pasuruan from 1970 until she departed Indonesia in 2011 and that she worked in [a job task] at two [work sites] in Pandaan. The form did not provide details of any family and no further evidence was submitted to the Department.
On 29 June 2016, a delegate of the Minister for Immigration refused to grant the applicant a protection visa.
Application for merits review
The applicant submitted three applications for merits review of the single decision to refuse her a protection visa. The current application was made on 14 July 2016 and the subsequent two applications have been discontinued.
On 22 May 2019, the applicant attended a hearing. The hearing was conducted with the assistance of an interpreter in the Indonesian and English languages. At the hearing, the applicant gave evidence that she met her former partner when she worked as [a job task] in Pandaan in around 1987. They lived together from 1988 and he became violent around that time.
The applicant described [Mr A] as a womaniser. Each time she would raise the issue with him, he would raise his hand. The applicant explained that the final time this happened was the last straw. He beat her until her leg was broken and she was hospitalised. I asked the applicant when this occurred and she initially gave evidence that it occurred around two years after they started living together. The applicant was confused about the dates. She guessed that it was in 2000 and then amended her evidence to 2003. On reflection, she realised that this was fifteen years after they moved in together. Finally, she stated that she broke her leg in 1991, but it took fifteen years to recover.
Following the hearing, the applicant supplied the Tribunal with a letter from [Mr B], Medical Director at [Hospital], dated [May] 2019. The letter outlines that patient medical records show [the applicant] was an in-patient from [date] until [date] April 1993, with a diagnosis of [an injury].
The applicant gave evidence that after she broke her leg, her friend tried to ascertain which country could protect her, because Indonesia could not. She confirmed that she continued to live with her ex-boyfriend until she left for Australia. I asked the applicant why she remained living with her ex-boyfriend for such a long period of time if she considered the incident to be the last straw. She explained that she remained living with him because she had no idea what to do - she was alone. He would often go away, however the applicant was not sure where he would go and if she questioned him, he would become angry. [Mr A] continued to physically assault her regularly, and would often hit her head or punch her face.
I asked if the applicant ever tried to move elsewhere. She said no, she had no other residence.
I questioned if the applicant reported the assault to police. She said that she went to the station in Pandaan after she was discharged from hospital. They took notes and she filled in a form, but nothing happened. I questioned if the applicant went to the police on any other occasion. She gave evidence that she would go often. On one occasion she went daily for ten days. The police would say ‘yes, yes, yes’, but there was no follow-up. When I asked if the applicant knew why the police would not assist her, she speculated that the police did not assist her because in Indonesia you need money to get help.
The applicant gave evidence that she has not communicated with [Mr A] since her arrival in Australia. Given the passage of time, I questioned if he would still try to find her and hurt her if she returned to Indonesia. The applicant was confident that [Mr A] would hurt her and may kill her.
The applicant’s father lived nearby to the couple. When they quarrelled, [Mr A] would commit violence against her father and wanted to kill him. She explained that there was an incident during which [Mr A] placed a knife against her father’s neck. I asked the applicant what her father would do during these incidents. She explained that her father was old and would do nothing. I asked the applicant about her father’s death. She gave evidence that he died when his car crashed into a tree in about 1993. There were no other cars involved.
I asked the applicant if she would be in a position to live in another area of Indonesia. In response, she explained that she is alone and wouldn’t have a clue where to go. I highlighted that the applicant had successfully relocated to Australia, which indicates that she is able to move to a new and unknown area. In addition, Indonesia has a large population and is geographically spread across multiple islands, which might provide some protection against being located.
When questioned about the four year delay between her arrival in Australia and applying for protection, the applicant explained that she was unaware of the correct visa. If she had known, she would have applied on arrival.
Credibility
The Tribunal is aware of the importance of adopting a reasonable approach in the finding of credibility. In Minister for Immigration and Ethnic Affairs and McIllhatton v Guo Wei Rong and Pam Run Juan,[1] the Full Federal Court made comments on determining credibility. The Tribunal notes in particular the cautionary note sounded by Foster J at [482]:
care must be taken that an over-stringent approach does not result in an unjust exclusion from consideration of the totality of some evidence where a portion of it could reasonably have been accepted.
[1] (1996) 40 ALD 445
The Tribunal also accepts that ‘if the applicant’s account appears credible, [s]he should, unless there are good reasons to the contrary, be given the benefit of the doubt’ (The United Nations High Commissioner for Refugees’ Handbook on Procedures and Criteria for Determining Refugee Status, Geneva, 1992 at para 196). However, the Handbook also states (at para 203):
The benefit of the doubt should, however, only be given when all available evidence has been obtained and checked and when the examiner is satisfied as to the applicant's general credibility. The applicant's statements must be coherent and plausible, and must not run counter to generally known facts.
I note that the mere fact that a person claims fear of persecution for a particular reason does not establish the genuineness of the asserted fear, that the fear is “well-founded” or that it is for the reason claimed. A fear of persecution is not “well-founded” if it is simply assumed or if it is mere speculation.
Although the concept of onus of proof is not appropriate to administrative inquiries and decision-making, the relevant facts of the individual case will have to be supplied by the applicant, in as much detail as is necessary to enable the examiner to establish the relevant facts. A decision-maker is not required to make the applicant's case for them. Nor is the Tribunal required to accept uncritically any and all the allegations made by an applicant.[2]
[2] MIEA v Guo & Anor (1997) 191 CLR 559 at 596, Nagalingam v MILGEA (1992) 38 FCR 191, Prasad v MIEA (1985) 6 FCR 155 at 169 70.
In addition, 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 established. Nor is the Tribunal obliged to accept claims that are inconsistent with the independent evidence regarding the situation in the applicant's country of nationality.[3]
Assessment of claims
[3] See, Randhawa v MILGEA (1994) 52 FCR 437 at 451, per Beaumont J; Selvadurai v MIEA & Anor (1994) 34 ALD 347 at 348 per Heerey J and Kopalapillai v MIMA (1998) 86 FCR 547.
I accept that the applicant is a single Indonesian woman of Chinese heritage. I accept that she fractured her tibia in 1993 and was admitted to hospital for treatment. However, I have serious concerns about the credibility of the applicant’s evidence in respect of her claims to have been physically assaulted or threatened by a man named [Mr A]. The applicant provided hesitant, vague and at times contradictory evidence when questioned about specific details of her claims. For example:
·At the hearing, when giving evidence as to the alleged assault resulting in her broken leg, the applicant stated that the very last time was the last straw. However, she went on to say that she remained living with her former partner for more than fifteen years and he would often hit her during that time.
·On her application for protection, the applicant outlined that she tried to move many times, but [Mr A] would locate her, possibly with the assistance of his brother who was in the police force. At the hearing she gave evidence that she never moved.
·On the application for protection form, the applicant speculated that her former partner was involved in her father’s death on the basis that [Mr A] was friends with the driver of the car. At the hearing, the applicant gave evidence that her father was the driver in a single car accident. When I asked her about this at the hearing, she said ‘I don’t know’. This evidence is in direct conflict and is not readily explained by a lack of English comprehension.
·When questioned about why the police would not provide her with assistance when she made reports, the applicant gave evidence that in order to get assistance from the Indonesian police you need money. However on her application form she stated that the police would not assist her because [Mr A]’s brother was a police officer. At the hearing, I highlighted that the applicant had alleged [Mr A] had a family member that worked for the police. In response, she said that her former partner had an extended family member in the police, not a close one.
When I raised the apparent inconsistencies between the applicants written and oral evidence with the applicant at the hearing, she explained that at the time she completed her application form she had limited comprehension of English. She confirmed that she completed the form herself without assistance. While I accept that language difficulties may lead to minor anomalies, I do not accept that the applicant’s limited comprehension would result in the provision of directly conflicting evidence.
In addition to the above concerns with aspects of the applicant’s evidence, I note that delay in seeking a protection visa can support an adverse credibility finding as well as a finding that the applicant does not have a well-founded fear of harm.[4] The applicant applied for a protection visa on 21 June 2015, more than four years after she arrived in Australia. At the time she applied, the applicant was in Australia unlawfully and had limited options to remain. When questioned about the delay in lodging a protection application, the applicant said she was unaware of the correct visa. If she had known, she would have applied on arrival. I do not find this to be a convincing justification for the delay. Failure to seek assistance or question the available visa options for such an extended period is not indicative behaviour of someone who feared for their physical safety from the day of arrival.
[4] Zhang v RRT & Anor [1997] FCA 423; Kavan v MIMA [2000] FCA 370.
Considering all of the evidence cumulatively and having regard to the applicant’s narrative as a whole, I do not find the applicant to be credible. For these reasons, I do not accept that the applicant was ever physically assaulted or threatened by an individual named [Mr A] or that she would be harmed by him or any other person in the foreseeable future.
Chance of harm if returned to Indonesia
The applicant claims to fear harm from her former partner if she were to return to Indonesia. As outlined above, I do not accept that the applicant was physically assaulted by an individual named [Mr A], or that an individual by that name would seek to locate or harm the applicant on return.
I have considered cumulatively what I have accepted of the applicants claim and find that the applicant does not face a real chance of serious harm, now and into the reasonably foreseeable future, for any reason if she were returned to Indonesia. I therefore find that the applicant is not a refugee within the meaning of s.5H and does not fall within Australia’s protection obligations under s.36(2)(a).
For the same reasons that I found there is no real chance of serious harm, I find that the real risk element of the test in s.36(2)(aa) has not been met.[5] I find that there are no substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to India there is a real risk that he will suffer significant harm: s.36(2)(aa).
[5] as per the judgment in MIAC vSZQRB [2013] FCAFC 33.
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.
Sheridan Lee
MemberATTACHMENT - Extract from Migration Act 1958
5 (1) Interpretation
…
cruel or inhuman treatment or punishment means an act or omission by which:
(a) severe pain or suffering, whether physical or mental, is intentionally inflicted on a person; or
(b) pain or suffering, whether physical or mental, is intentionally inflicted on a person so long as, in all the circumstances, the act or omission could reasonably be regarded as cruel or inhuman in nature;
but does not include an act or omission:
(c) that is not inconsistent with Article 7 of the Covenant; or
(d) arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
degrading treatment or punishment means an act or omission that causes, and is intended to cause, extreme humiliation which is unreasonable, but does not include an act or omission:
(a) that is not inconsistent with Article 7 of the Covenant; or
(b) that causes, and is intended to cause, extreme humiliation arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
torture means an act or omission by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person:
(a) for the purpose of obtaining from the person or from a third person information or a confession; or
(b) for the purpose of punishing the person for an act which that person or a third person has committed or is suspected of having committed; or
(c) for the purpose of intimidating or coercing the person or a third person; or
(d) for a purpose related to a purpose mentioned in paragraph (a), (b) or (c); or
(e) for any reason based on discrimination that is inconsistent with the Articles of the Covenant;
but does not include an act or omission arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
receiving country, in relation to a non-citizen, means:
(a) a country of which the non-citizen is a national, to be determined solely by reference to the law of the relevant country; or
(b) if the non-citizen has no country of nationality—a country of his or her former habitual residence, regardless of whether it would be possible to return the non-citizen to the country.
…
5H Meaning of refugee
(1)For the purposes of the application of this Act and the regulations to a particular person in Australia, the person is a refugee if the person is:
(a) in a case where the person has a nationality – is outside the country of his or her nationality and, owing to a well-founded fear of persecution, is unable or unwilling to avail himself or herself of the protection of that country; or
(b) in a case where the person does not have a nationality – is outside the country of his or her former habitual residence and owing to a well-founded fear of persecution, is unable or unwilling to return to it.
Note: For the meaning of well-founded fear of persecution, see section 5J.
…
5J Meaning of well-founded fear of persecution
(1)For the purposes of the application of this Act and the regulations to a particular person, the person has a well-founded fear of persecution if:
(a) the person fears being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion; and
(b) there is a real chance that, if the person returned to the receiving country, the person would be persecuted for one or more of the reasons mentioned in paragraph (a); and
(c) the real chance of persecution relates to all areas of a receiving country.
Note: For membership of a particular social group, see sections 5K and 5L.
(2)A person does not have a well-founded fear of persecution if effective protection measures are available to the person in a receiving country.
Note: For effective protection measures, see section 5LA.
(3)A person does not have a well-founded fear of persecution if the person could take reasonable steps to modify his or her behaviour so as to avoid a real chance of persecution in a receiving country, other than a modification that would:
(a) conflict with a characteristic that is fundamental to the person’s identity or conscience; or
(b) conceal an innate or immutable characteristic of the person; or
(c) without limiting paragraph (a) or (b), require the person to do any of the following:
(i)alter his or her religious beliefs, including by renouncing a religious conversion, or conceal his or her true religious beliefs, or cease to be involved in the practice of his or her faith;
(ii)conceal his or her true race, ethnicity, nationality or country of origin;
(iii)alter his or her political beliefs or conceal his or her true political beliefs;
(iv)conceal a physical, psychological or intellectual disability;
(v)enter into or remain in a marriage to which that person is opposed, or accept the forced marriage of a child;
(vi)alter his or her sexual orientation or gender identity or conceal his or her true sexual orientation, gender identity or intersex status.
(4)If a person fears persecution for one or more of the reasons mentioned in paragraph (1)(a):
(a) that reason must be the essential and significant reason, or those reasons must be the essential and significant reasons, for the persecution; and
(b) the persecution must involve serious harm to the person; and
(c) the persecution must involve systematic and discriminatory conduct.
(5)Without limiting what is serious harm for the purposes of paragraph (4)(b), the following are instances of serious harm for the purposes of that paragraph:
(a) a threat to the person’s life or liberty;
(b) significant physical harassment of the person;
(c) significant physical ill‑treatment of the person;
(d) significant economic hardship that threatens the person’s capacity to subsist;
(e) denial of access to basic services, where the denial threatens the person’s capacity to subsist;
(f) denial of capacity to earn a livelihood of any kind, where the denial threatens the person’s capacity to subsist.
(6)In determining whether the person has a well‑founded fear of persecution for one or more of the reasons mentioned in paragraph (1)(a), any conduct engaged in by the person in Australia is to be disregarded unless the person satisfies the Minister that the person engaged in the conduct otherwise than for the purpose of strengthening the person’s claim to be a refugee.
5K Membership of a particular social group consisting of family
For the purposes of the application of this Act and the regulations to a particular person (the first person), in determining whether the first person has a well‑founded fear of persecution for the reason of membership of a particular social group that consists of the first person’s family:
(a) disregard any fear of persecution, or any persecution, that any other member or former member (whether alive or dead) of the family has ever experienced, where the reason for the fear or persecution is not a reason mentioned in paragraph 5J(1)(a); and
(b) disregard any fear of persecution, or any persecution, that:
(i)the first person has ever experienced; or
(ii)any other member or former member (whether alive or dead) of the family has ever experienced;
where it is reasonable to conclude that the fear or persecution would not exist if it were assumed that the fear or persecution mentioned in paragraph (a) had never existed.
Note: Section 5G may be relevant for determining family relationships for the purposes of this section.
5L Membership of a particular social group other than family
For the purposes of the application of this Act and the regulations to a particular person, the person is to be treated as a member of a particular social group (other than the person’s family) if:
(a) a characteristic is shared by each member of the group; and
(b) the person shares, or is perceived as sharing, the characteristic; and
(c) any of the following apply:
(i)the characteristic is an innate or immutable characteristic;
(ii)the characteristic is so fundamental to a member’s identity or conscience, the member should not be forced to renounce it;
(iii)the characteristic distinguishes the group from society; and
(d) the characteristic is not a fear of persecution.
5LA Effective protection measures
(1)For the purposes of the application of this Act and the regulations to a particular person, effective protection measures are available to the person in a receiving country if:
(a) protection against persecution could be provided to the person by:
(i)the relevant State; or
(ii)a party or organisation, including an international organisation, that controls the relevant State or a substantial part of the territory of the relevant State; and
(b) the relevant State, party or organisation mentioned in paragraph (a) is willing and able to offer such protection.
(2)A relevant State, party or organisation mentioned in paragraph (1)(a) is taken to be able to offer protection against persecution to a person if:
(a) the person can access the protection; and
(b) the protection is durable; and
(c) in the case of protection provided by the relevant State—the protection consists of an appropriate criminal law, a reasonably effective police force and an impartial judicial system.
…
36 Protection visas – criteria provided for by this Act
…
(2)A criterion for a protection visa is that the applicant for the visa is:
(a) a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee; or
(aa) a non-citizen in Australia (other than a non-citizen mentioned in paragraph (a)) 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 non-citizen being removed from Australia to a receiving country, there is a real risk that the non-citizen will suffer significant harm; or
(b) a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (a); and
(ii)holds a protection visa of the same class as that applied for by the applicant; or
(c) a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (aa); and
(ii)holds a protection visa of the same class as that applied for by the applicant.
(2A)A non‑citizen will suffer significant harm if:
(a) the non‑citizen will be arbitrarily deprived of his or her life; or
(b) the death penalty will be carried out on the non‑citizen; or
(c) the non‑citizen will be subjected to torture; or
(d) the non‑citizen will be subjected to cruel or inhuman treatment or punishment; or
(e) the non‑citizen will be subjected to degrading treatment or punishment.
(2B)However, there is taken not to be a real risk that a non‑citizen will suffer significant harm in a country if the Minister is satisfied that:
(a) it would be reasonable for the non‑citizen to relocate to an area of the country where there would not be a real risk that the non‑citizen will suffer significant harm; or
(b) the non‑citizen could obtain, from an authority of the country, protection such that there would not be a real risk that the non‑citizen will suffer significant harm; or
(c) the real risk is one faced by the population of the country generally and is not faced by the non‑citizen personally.
…
Key Legal Topics
Areas of Law
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Immigration
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Statutory Interpretation
Legal Concepts
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Judicial Review
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Procedural Fairness
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Statutory Construction
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Remedies
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