1611309 (Refugee)

1611309 (Refugee) [2016] AATA 4526 (5 October 2016)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  1611309
COUNTRY OF REFERENCE:                  Vietnam
MEMBER:Carolyn Wilson
DATE:5 October 2016
PLACE OF DECISION:  Adelaide
DECISION:The Tribunal affirms the decision not to grant the applicant a protection visa.

Statement made on 05 October 2016 at 11:44am
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 [in] July 2016 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 Vietnam applied for the visa [in] May 2016. The delegate refused to grant the visa [in] July 2016.
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 themself 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.56, made under s.499 of the Act, the Tribunal has taken 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 relevant 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
For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
The applicant is [an age] year old married woman from Vietnam. She arrived in Australia in March 2010 as the holder of a [temporary] visa, which ceased one month later. She remained in Australia without a visa. She was arrested in May 2015 and charged with the offence ‘[specified charge]. She was held in criminal detention from that time, but released in June 2016 without conviction. She has been held in immigration detention since that time.
The applicant says she came to Australia to escape her violent husband. She claims to fear returning to Vietnam because she fears he will kill her or force her into prostitution. Her husband has [specified] addictions and he has forced her to send money to him from Australia. Although she left her [child] with [Relative 1] when she left Vietnam, her [Relative 1] has since died and the husband has taken custody of the [child]. He threatens to harm the [child] if she does not send money. The authorities will not protect her because her family has a history of being reactionary against communism. Her [Relative 1] and [sibling] have been persecuted in the past for this reason.
The delegate refused the application as they did not find the claims to be credible. The delegate came to this conclusion after taking into account the inconsistencies in the claims and the delay in seeking protection.
On review the applicant provided a copy of the decision record, a transcript of the interview with the delegate, written submissions and country information from the representative, and a written statement from the applicant.
At hearing the applicant repeated her claims that she left Vietnam because of her violent husband. She claims a relative paid for her to come to Australia to help her out of the bad situation with her husband. She left her [child], then aged [age], in Vietnam because she didn’t know she could bring [the child]. She also left Vietnam to help her family, including her [Relative 1’s] medical expenses, by sending money from working in Australia. She says she is still in contact with her husband and calls him about once a month.
Findings on credibility
The applicant came to Australia on a one month [temporary] visa with the intention of overstaying her visa to work and send money to Vietnam. The applicant concedes this, however also claims she came and stayed to escape her violent husband.
The Tribunal notes the applicant did not seek protection until she was arrested. The applicant spent 5 years in Australia unlawfully. The applicant has successfully found work throughout her time in Australia, joined a church community, and obtained a drivers licence. The Tribunal finds she would have had the social contacts and ability to seek help and advice on applying for protection, if she had a genuine fear of returning to Vietnam.
The Tribunal is concerned by a significant inconsistency in the applicant’s claims, which leads it to doubt the veracity of her claims generally. In her written claims (f.49 of the Department file) she stated the following:
‘[My husband] forced me to become a prostitute…
‘My husband…often beat me and forced me to make money for him by become [sic] a prostitute…
‘If I return to Viet Nam my husband will beat, kill me and force me to return to my old life which I always feel disgusting and shamed about. It is because he wants me to make money to pay for his debt’.
The applicant again made this claim in a written statement provided with her application (f. 45 of the Department file). However, at the Tribunal hearing she said he husband had suggested she work as a prostitute, however she was always able to resist the suggestion. She denied ever working as a prostitute. She said she worked as [an occupation] or in the markets instead. She also claims to have worked selling [product].
The Tribunal finds her willingness in written claims to fabricate past work as a prostitute is indicative of an inclination to exaggerate or fabricate stories about her life in Vietnam, in order to fabricate claims to meet the criteria for a Protection visa.
The Tribunal is also concerned by the inconsistencies in the applicant’s claimed work and education history. She claims to have studied at school for only [time period], from [specified year] to [year], when she was [age] years old. However, she claims to have worked selling [product] in Vietnam from [year span], whilst completing a training course with the [company]. It was on the basis of this employment that she was granted a [temporary] visa to come to Australia. The Tribunal does not accept someone with [such limited] primary school education would be able to complete a training course and work in a job selling [product]. The Tribunal put this inconsistency to the applicant at hearing, however she maintained she had completed training and had worked selling [product]. The Tribunal finds the applicant is not being truthful, but does not know whether it is her educational or work history that she is lying about. The Tribunal finds her willingness to continue to lie about it raises real concerns about her credibility generally.
The Tribunal is also concerned as to why the applicant was in contact, and remains in contact, with her husband, if he was as violent as she says. The applicant says she is in contact with her husband so that she can maintain contact with her [child]. However, the applicant claims to have left her [child] in the care of [Relative 1] and a [another relative] when she left Vietnam. There was therefore no need for her to contact her husband when she first came to Australia. The Tribunal acknowledges the applicant’s [Relative 1] has since died and the applicant says the [child] returned to [the] father’s care. However, the Tribunal also notes the applicant has now been in detention, either criminal or immigration, for [number] months, and has been unable to work and send money to Vietnam during this period. Yet there is no claim that any harm has come to her [child]. The Tribunal finds the applicant has fabricated the claim that she has kept in contact with her husband and sends him money, only because he has threatened to harm their [child] if she does not. The Tribunal finds she has maintained contact and sent money because this is what she always intended to do, that is, come to Australia to earn more money and send money back to her family, including to her husband,. The Tribunal finds the applicant has exaggerated or fabricated her husband’s [addictions], and has fabricated the claims that he has forced her to send money.
The applicant concedes she had around $[amount] cash on her when she was arrested by the [police]. She had already sent $[amount] to her husband in Vietnam just prior to being arrested, and kept this money for herself. She says the money was for her holiday [and] to pay for dental work. The Tribunal finds this is inconsistent with her claims that she had to send money to her husband to stop him from carrying out his threats to harm their [child].
The Tribunal has considered the oral evidence of the witness who came to the [hearing]. The witness said she shared a bedroom with the applicant in [another city] in 2013. She said she overheard some telephone conversations between the applicant and her husband. She heard the husband demanding money and threatening the applicant. The Tribunal asked how she could hear what the husband was saying and the witness said the applicant had the phone on speakerphone. The Tribunal finds this highly unlikely. Given the witness’s evidence that she was in her bedroom studying when these calls came in, the Tribunal finds the applicant would not have put the phone on speakerphone, but would have left the room or spoken quietly on the phone. The Tribunal gives the evidence from the witness little weight. The Tribunal finds the witness’ evidence does not overcome the concerns raised above.
The Tribunal has concluded there are too many inconsistencies and some fabrications in the applicant’s account for it to be credible. The Tribunal does not accept the applicant fears violence from her husband as she claims, and does not accept she fears he will harm her if she returns. The Tribunal finds the applicant came to Australia to work and earn more money. When she has sent money to Vietnam, this was done voluntarily and was part of her reason for coming to work in Australia.
Refugee criterion
At hearing the Tribunal asked the representative if the applicant claimed to meet the Refugee criterion or Complementary Protection criterion or both. The representative said she claimed to meet both, and that the claims fell under the Refugee criterion because the applicant feared harm in Vietnam as a member of the particular social group ‘women in Vietnam’. However, for the reasons given above, the Tribunal does not accept the applicant’s claims to fear violence from her husband are genuine. The Tribunal has therefore not found it necessary to consider whether her husband has targeted her for personal reasons, rather than one or more of the 5 reasons in s.5J, or whether the state would withhold protection from her because she is a member of a particular social group ‘women in Vietnam’.
The Tribunal notes the applicant has disclosed past instances of sexual abuse by relatives and a neighbour when she was a child, and a rape by a stranger when she moved to Saigon to work in a factory at [age] year old. The Tribunal acknowledges these are traumatic events. However, the Tribunal does not accept that because the applicant was the victim of sexual violence as a minor that it follows she has a real chance of being persecuted in this way again.
The applicant claims her family have suffered in the past in Vietnam for political and religious reasons, and this is a reason the authorities would not protect her from her husband. As found above, the Tribunal does not accept her claims to fear violence from her husband, and therefore does not need to consider whether the authorities would withhold protection. In relation to the claims of past wrongs to her [Relative 1] and [siblings], there is no evidence or clams the applicant herself was persecuted by the authorities in the past, and no claim she fears persecution for reason of her relationship to her late [Relative 1] or [siblings]. The Tribunal does not accept the applicant has a well-founded fear of persecution for reason of her relationship to her late [Relative 1] or [siblings].
Whilst the applicant’s claims have focused on her claim to fear harm from her husband, she has also claimed that as a Catholic she has a well-founded fear of persecution in Vietnam. The DFAT Country information Report Vietnam (31 August 2015) provides the following information on the situation for Catholics in Vietnam:
3.15 Article 24 of the Constitution allows citizens to enjoy freedom of belief and religion, and to follow any religion or none. It also states that all religions are equal before the law, and that no one may ‘misuse beliefs and religions to contravene the law and State policies’. The Penal Code 1999 includes penalties for offenses such as ‘Undermining the unity policy … [through promoting] division between religious believers and nonbelievers’.
3.16 The government implements a registration process for religious organisations, with an approval process managed by the Committee on Religious Affairs (CRA). Under the government’s ‘Decree 92’ of January 2013, religious organisations may be registered if they can demonstrate that they have operated for 20 years within Vietnam without violation of Vietnamese law. They are also required to commit to upholding government regulations and to ensure their activities support the ability of the state to maintain public order. There are 38 registered religious organisations affiliated with 13 officially recognised religions, including Buddhism, Christianity, Islam, Judaism, Cao Dai, and Hoa Hao. Registered clergy may conduct religious education in approved religious facilities. Most recognised religions in Vietnam also have one or more groups that are not recognised or registered.
3.17 The government maintains a dedicated police force for monitoring the activities and networks of religious organisations in Vietnam. The force is responsible to the Ministry of Public Security and sets and administers policies for the enforcement of state law against non-registered religious groups who are perceived by the Government of Vietnam to threaten national stability.
3.18 In practice, the authorities’ treatment of religious activity varies across
Vietnam, particularly for unregistered organisations. Groups that are under surveillance for alleged separatist activities may find administrators more likely to apply more stringent measures, including surveillance and harassment of public religious gatherings.
3.19 Broadly speaking, DFAT assesses that as long as religious practice is exercised within state-sanctioned boundaries and does not challenge the interests or authority of the Government of Vietnam—which can be broadly defined and include land use issues—religious adherence in Vietnam is tolerated, even for some religions not officially recognised by the government. There may, however, be restrictions on some activities and the freedom of individuals to travel outside of Vietnam to attend religious festivals and events. There are credible reports of restrictions on the activities of some unregistered groups, including allegations of violence and harassment, which are discussed in more detail in following sections. DFAT is not aware of credible claims of societal abuse or systemic discrimination based on religious practices. Authorities are, however, concerned about the potential for religious groups to be mobilised for political purposes.
…
3.22 The Catholic Church is registered in Vietnam and in recent years has had some restrictions on charitable activities lifted. A number of new church congregations were approved in 2013, mostly in the Central and Northwest Highlands areas in response to increased demand from the growing Catholic communities in the area, although many more registration requests are still pending.
3.23 Members of independent Catholic groups opposed to government policies have been subject to harassment by authorities. While exact numbers are unavailable, reliable sources suggest that over 30 activists associated with Catholic churches have been arrested since 2011 (out of an estimated Catholic population of approximately 6.5 million). While some have been charged with ‘crimes against the State’, others are yet to be formally charged. According to the 2013 US State Department’s International Religious Freedom report, in July 2013 police forcibly removed a group of Catholics who had been praying in front of a church in Ho Chi Minh City, having travelled from other provinces to worship after land and property had
allegedly been seized by local authorities. Several members of the group reportedly required hospitalisation after being beaten by police.
3.24 Nonetheless, DFAT assesses that Catholics in Vietnam who worship quietly and in a manner that conforms to government policies and sensitivities are able to do so with a low risk of official interference.
The applicant confirmed at hearing that she attended a Catholic church when she lived in Vietnam, but has never held a leadership role or been involved in any protest activity. She has never been prevented from practising her faith in Vietnam. She has never experienced any serious harm for reason of her religion. Relying on her low level practice of the religion, as an ordinary Catholic and not a leader or activist, the lack of any past harm for her religious beliefs and activities, and taking into account the information form the DFAT report, the Tribunal finds the applicant does not have a well-founded fear of persecution for reason of her religion.

The Tribunal finds the applicant does not have a well-founded fear of persecution for any of the reasons set out in s.5J. The Tribunal find she does not meet the definition of refugee as defined in s.5H, and therefore does not meet the requirements of s.36(2)(a).
Complementary protection criterion
The Tribunal has also assessed the applicant’s claim under the Complementary Protection criterion. It has considered whether there are substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to Vietnam, there is a real risk that she will suffer significant harm
For the reasons given above, the Tribunal finds the applicant came to Australia with the intention to work. The Tribunal does not accept she genuinely fears harm from her husband, or that there is any objective basis to find she faces a real risk of harm from him.
For the reasons given above, the Tribunal also finds there is not a real risk the applicant will suffer harm because she is Catholic, a woman, a victim of sexual violence as a minor, or because her [Relative 1] and [siblings] were targeted in the past.
The Tribunal is not satisfied there are substantial grounds for finding the applicant faces a real risk of significant harm as a necessary and foreseeable consequence of her being removed from Australia to Vietnam. She does not meet s.36(2)(aa).
Conclusion
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 s.36(2)(a).
Having concluded that the applicant does not meet the refugee criterion in s.36(2)(a), the Tribunal has considered the alternative criterion in s.36(2)(aa). 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.
Carolyn Wilson
Member

ATTACHMENT - 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.
…
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 them 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.
..
36Protection visas – criteria provided for by this Act
…
(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.
…

[2016] AATA 4526

5 October 2016

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Immigration

Administrative Law

Statutory Interpretation

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Judicial Review

Procedural Fairness

Statutory Construction

Natural Justice

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