1700239 (Refugee) - [2018] AATA 1298

1700239 (Refugee) [2018] AATA 1298 (27 April 2018)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  1700239
COUNTRY OF REFERENCE:                  Palestinian Terr. (W.Bank/Gaza)
MEMBER:Irene O'Connell
DATE:27 April 2018
PLACE OF DECISION:  Sydney
DECISION:The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s.36(2)(a) of the Migration Act.

Statement made on 27 April 2018 at 9:30am
CATCHWORDS
Refugee – Protection Visa – Palestinian Territories (West Bank / Gaza) – Whether the applicant is excluded from consideration by operation of Article 1D of the Convention – Ministerial Direction 56 – Consistency in decision making – Procedural Advice Manual (PAM) – Refugee Law Guidelines - Article 1D no longer operative under Australian law for decisions on or after 16 December 2014
Refugee – Protection Visa – Palestinian Territories (West Bank / Gaza) – Political opinion – Student activist – Fear of harm from Hamas – Previous adverse interactions with Hamas - Country information supports applicant’s claims – Evidence of human rights situation in Gaza deteriorating
LEGISLATION
Migration Act 1958, ss 36(2)(a), 65, 91R, 91S
Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Legacy Caseload) Act 2014
Migration Regulations 1994
CASES
MIMA v WABQ [2002] FCAFC 329
Al-Khateeb v Minister for Immigration and Multicultural Affairs [2002] FCA 7
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
Background

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 arrived in Australia [in] June 2014 on a prospective marriage visa. [In] July 2014 her relationship with her fiancé ceased. [In] August 2014 she lodged an application for a protection visa. This was refused [in] December 2016 and the applicant sought review of this decision on 5 January 2017.
Since lodging her application for a protection visa she has married an Australian citizen and has two children by this marriage. She is currently studying. Her parents and siblings reside in Gaza.
The applicant resided in [a particular refugee camp] from her birth until she was 11 years of age. She and her family are registered with the United Nations Relief and Works Agency (UNRWA). She is the holder of a Palestinian passport.
The applicant has applied for protection on the basis of her political opinion. She claims to have joined the Popular Front for the Liberation of Palestine (PFLP) when at school. She continued her involvement when a student at [a particular university] in Gaza, where she commenced a [particular course], and while at [another university], where she completed [further studies].
The applicant claims that her political activities brought her to the adverse attention of the Hamas General Intelligence who detained her and questioned her. She claims that she was monitored by Hamas from 2008 until her departure from Gaza in 2014.
EVIDENCE BEFORE THE TRIBUNAL
The Tribunal as before it the Department of Immigration (the Department) file in respect to the applicant’s prospective spouse visa application. The Tribunal also has before it [Department file] in respect to the applicant’s protection visa application. This file contains the applicant’s protection visa application, a recording of an interview between the applicant and a delegate of the Minister held [in] October 2016, and the decision record of the delegate refusing the grant of the visa.
The file also contains documentary evidence submitted by the applicant. This material includes:
·A statutory declaration made by the applicant (dated [in] August 2014) setting out her claims
·A copy of a letter from the Department granting approval of the applicant’s Subclass 300 visa dated ([April] 2014)
·The applicant’s family registration document with UNRWA dated [in] November 2012
·A photocopy of the applicant’s passport issued by the Palestinian Authority (PA)
·A translation from Arabic of the applicant’s membership card for the PFLP with the validity date of [a particular date in] 2016 and copy of the untranslated document
·A translation from Arabic of a document issued to the applicant by the Palestinian Intelligence Agency for an obligatory request for interrogation on [a particular date in] 2010 and a copy of the untranslated document
·Country information in the form of newspaper articles about political events in Palestine and the PFLP
·A copy of a Queensland marriage certificate for the applicant dated [in] 2015, issued on [a later date in] 2015
·A birth certificate for the applicant’s child born [birth date], issued on [a particular date].
Several of these documents were also submitted to the Tribunal with the applicant’s application for review. The applicant provided to the Tribunal a copy of her renewed Palestinian passport and news articles related to the treatment of PFLP members by Hamas.
In her written submission to the Tribunal the applicant explains that her involvement in the PFLP was as a moderate Muslim not as a radical and she was not involved in any violent activities which some elements of the PFLP have engaged.
In her oral evidence to the Tribunal given at hearing on 11 April 2018 the applicant stated that she fears mistreatment from Hamas if she were to return to Gaza. She indicated that her parents and [siblings] currently reside in Gaza and that they have been questioned by Hamas. She also stated that it is a common practice for Hamas to bus their political opponents to the so called Green Line and border areas where there is armed conflict with the Israeli military.
The applicant described her involvement with the PFLP during her student days and how this had brought her to the adverse attention of Hamas and the PA. She stated that as the eldest sibling she was the first to be politically active and that her siblings are more cautious.
The applicant indicated that her family were registered with UNRWA as her paternal grandfather was forced off his land in the conflict of 1948. She indicated that she had lived in a refugee camp for a number of years and attended a school run by UNRWA. When asked whether UNRWA provided her with protection, she stated that they provided services but were currently struggling to do even this. She stated that because of the blockade currently in force her father, who has suffered a [serious medical emergency], is unable to access necessary medical assistance. She stated that her siblings although educated are unable to find any work and that the family relies on handouts to survive.
RELEVANT LAW
As the applicant’s application was lodged on 20 August 2014 the relevant law is the criterion in s.36(2)(a) of the Act that was in force before 16 December 2014. 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).
Article 1A(2) of the Convention 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.
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’).
Article 1D of the Refugees Convention is an exclusion clause with particular relevance to Palestinian refugees. It states that:
This Convention shall not apply to persons who are at present receiving from organs or agencies of the United Nations, other than the United Nations High Commission for Refugees, protection or assistance.
When such protection or assistance has ceased for any reason, without the position of such persons being definitively settled in accordance with the relevant resolutions adopted by the General Assembly of the United Nations, these persons shall ipso facto be entitled to the benefits of this Convention.
FINDINGS AND REASONS
Country of reference
On the basis of the applicant’s passport, a copy of which was provided to the Tribunal, and on the basis of her UNRWA registration card, the Tribunal finds that the applicant is a Palestine refugee as so described in the DFAT Thematic Report Palestinian Territories (dated 15 March 2017):
The UN Relief and Works Agency for Palestine Refugees in the Near East (UNRWA) defines a ‘Palestine refugee’ as someone ‘whose normal place of residence was Palestine during the period 1 June 1946 to 15 May 1948, and who lost both home and means of livelihood as a result of the 1948 conflict’. UNRWA allows descendants of these refugees to be registered with them, even where registered descendants have obtained citizenship in third countries, such as Jordan. Most Palestinians in Jordan are Jordanian citizens. Palestinians in Lebanon are rarely citizens. UNRWA provides services and manages camps for Palestinian refugees in Jordan, Lebanon, Syria, the Gaza Strip and the West Bank (including east Jerusalem).
As the applicant is a Palestine refugee it is necessary to consider whether by operation of Article 1D of the Refugees Convention the applicant is excluded from consideration under Article 1A(2) of the Convention.
Is the applicant excluded from consideration under Article 1A(2) by the operation of Article1D?
Article 1D of the Refugees Convention has been interpreted differently in different jurisdictions. Most noticeably, the English and European courts have interpreted Article 1D in a manner that is quite different from that of the Australian courts.
MIMA v WABQ [2002] FCAFC329 (WABQ)is taken to be the leading and definitive case on the operation and meaning of Article 1D in Australian law. It sets out the following:
·The word persons in the first and second paragraphs of the Article 1D, is to be read as a class of persons not an individual.
·The words at present in the ‘who are at present receiving assistance or protection’ is a reference to 28 July 1951 when the Refugees Convention was signed and is not a reference to the point in time in which the operation of Article 1D is considered in a particular case.
·The or of that same sentence should not be read as and as so suggested in an earlier judgment by Carr J in Al-Khateeb v Minister for Immigration and Multicultural Affairs [2002] FCA 7.
·The phrase ipso facto in the second paragraph is to be taken to mean that there is an entitlement to be assessed against Article 1A(2), not an automatic entitlement to protection under the Convention.
As set out in Procedural Advice Manual (PAM) PAM3 Refugee and humanitarian - Refugee Law Guidelines, the Full Federal Court’s interpretation of and observations about Article 1D resulted in a reading of the first paragraph of Article 1D in the Australian context in the following terms:
The first paragraph of Article 1D operates to exclude Palestinian refugees as a group from the benefits of the Convention if they were ‘at present’ (as at 28 July 1951 when the Convention was signed) receiving protection or assistance from organs or agencies of the United Nations other than UNHCR.
In terms of the meaning to be attributed to the second paragraph, it has been a common practice to consider the reference to protection to be a reference to the United Nations Conciliation Commission for Palestine (UNCCP) while the reference to assistance is taken to be reference to the UNRWA. This is because the Court in WABQ favoured this approach. PAM3 Refugee and humanitarian - Refugee Law Guidelines (dated 15 December 2014) sets it out as follows:
It was held that the second paragraph should be interpreted in line with the first, namely, that it applies to Palestinian refugees as a class of persons and ‘protection or assistance’ is to be read disjunctively. The question posed by the second paragraph of Article 1D is therefore whether protection by the UNCCP or assistance by UNRWA has ceased in relation to Palestinian refugees as a group, not whether it has ceased in respect of an individual. The court held that if either protection or assistance had ceased in relation to Palestinian refugees as a group, members of that group would not be excluded by Article 1D from the benefits of the Convention.
The Full Court held that the RRT was correct in finding that UNRWA still provided assistance. The issue of whether protection or assistance had ceased could therefore only be addressed by determining whether the UNCCP had actually embarked on its mandate to provide protection. This is because if no agency provided protection at the time the Convention was signed, there would be no agency which had ceased to provide protection.
The court referred back to the RRT the question of whether the UNCCP provided protection at the time the Convention was signed, and if so, whether that protection had ceased. The court made clear however, that it thought the UNCCP had embarked on its protection mandate and had ceased to provide that protection.
The RRT has since made findings in subsequent cases, based on independent evidence that by the early 1950s the UNCCP reached the conclusion that it was unable to fulfil its mandate. Since that time, it has not provided Palestinian refugees with the basic international protection accorded to other refugees. Independent evidence shows that the UNCCP has not been formally abolished but seems to be largely inactive.
The Tribunal is satisfied that this is a correct reading of the Full Federal Court’s interpretation of Article 1D and makes the following findings in respect to the application of Article 1D to the applicant.
The Tribunal finds that as a Palestinian refugee the applicant belongs to a class of persons which was receiving protection from the UNCCP and assistance from the UNRWA as at 28 July 1951.
The protection envisaged within Article 1D is the protection of durable solutions for Palestinian refugees as enshrined in the mandate of the UNCCP. The Tribunal finds that this protection ceased in relation to Palestinian refugees as a group when the UNCCP ceased providing protection.
The cessation of protection by the UNCCP is clearly articulated in a number of documents. For example a report on The United Nation Conciliation Commission for Palestine, Protection, and a Durable Solution for Palestinian Refugees (T.M. Rempel, June 2000) from the Badil Resource Centre for Palestinian Residency and Refugee Rights states that:
Since the early 1950s, however, the UNCCP has not provided Palestinian refugees with the basic international protection accorded to all other refugees …
The experience of the UNCCP is informative in relation to the provision of protection and implementation of a durable solution for Palestinian refugees. Analysis of the UNCCP clearly demonstrates how refugee rights may be compromised in the absence of an international protection body to promote the rights and choices of refugees at the negotiating table. The critical importance of refugee protection and the failure of the UNCCP to provide such protection raise urgent questions about the future of the Commission. The UNCPP was established by the United Nations in 1948 to provide protection and promote a durable solution for Palestine refugees, including repatriation, resettlement, restitution and compensation based on the choice of each refugee.

The Tribunal considers that it is irrelevant and unnecessary to consider whether protection has been re-enlivened. This is not what is envisaged or required by Article 1D.
The Tribunal also considers it misdirected to consider whether UNRWA provides protection. The UNRWA mandate is primarily that of assistance and reference to protection by UNRWA is of a lower and different order to the protection of a durable solution and basic international protection that was the mandate of the UNCCP.
Although in other jurisdictions bodies, such as the UK Home Office have considered UNRWA to provide protection, their Courts’ interpretation of Article 1D is at odds with that of the Australian Courts and as such are of little relevance. In WABQ the Court rejected the Tribunal’s finding that UNRWA provided protection.
The Tribunal places weight on the policy guidance contained within PAM3 Refugee and humanitarian - Refugee Law Guidelines. Ministerial Direction No.56 requires the Tribunal to take account of these guidelines. Direction 56 was issued with the purpose of facilitating consistent approaches to decision making. Given that Article 1D involves a finding about a class of persons, not just an individual it would be undesirable that decision makers make inconsistent findings about a class of persons.
The Tribunal notes that since WABQ there has been a consistent approach taken by decision makers at both first instance and at review in respect to the non-application of Article 1D to Palestine refugees. Indeed, as set out in PAM3 Refugee and humanitarian - Refugee Law Guidelines (accessed 13 October 2017), this approach is now firmly adopted into Australian law by way of the Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Legacy Caseload) Act 2014:
Article 1D deals with persons already receiving United Nations protection or assistance. It was specifically intended to apply to Palestinian refugees as they were the only class of persons who were receiving protection or assistance from agencies other than the UNHCR at the time the Refugees Convention was signed.
Prior to the introduction of the Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Legacy Caseload) Act 2014, Article 1D was not considered to be a relevant consideration to the refugee assessment under Australian law as per the Federal Court case of WABQ Minister for Immigration and Multicultural Affairs v WABQ. While WABQ relates to the Refugees Convention and predates the Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Legacy Caseload) Act 2014, the explanatory memorandum to the Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Legacy Caseload) Act 2014 makes it clear that Article 1D is still not a consideration for decision makers.
[T]he Government has not incorporated Article 1D into the new refugee framework due to the Full Federal Court’s finding in [WABQ] that Palestinian refugees, as a class of persons, do not fall within the scope of Article 1D, but are also not automatically entitled to the benefits of the Refugee Convention and should be assessed as to whether they are refugees within the meaning of Article 1A(2) of the Convention.
As such, and consistent with the findings in WABQ, any Palestinian refugee making claims for protection in Australia is to be considered against the definition of refugee under s5H of the Act.
For all the reasons set out above the Tribunal finds that Article 1D does not have application in respect to the applicant and it will consider her claims under Article 1A(2) of the Refugees Convention.
Is the applicant a refugee within the meaning of Article1A(2)?
As set out above the applicant claims that she faces serious harm on return to Gaza by reason of her political opinion.
The applicant claims to have had involvement in the PFLP during her student days. On the basis of her written and oral evidence and her documentary evidence in the form of a copy of her membership card of the PFLP the Tribunal accepts that the applicant was actively involved with this group in the years 2008–2010.
The Tribunal also accepts the applicant’s evidence that because of her political activities she was monitored and questioned by Hamas. The Tribunal accepts this because it is consistent with the country information provided by DFAT in its Thematic Report Palestinian Territories (dated 15 March 2017) which indicates that student activists are subject to monitoring by the PA and Hamas. It states as follows:
Beyond Fatah and Hamas there are a handful of political parties who describe a shrinking space for political opposition members in both the West Bank and Gaza. Some of these parties are members of the Palestine Liberation Organisation (PLO) and some are not. PLO factions include Fatah, the Popular Front for the Liberation of Palestine, the Palestinian National Initiative, the Third Way, the Democratic Front for the Liberation of Palestine, the Palestinian People’s Party and the Palestinian Democratic Union. Apart from Hamas, the non-PLO factions are the Palestine Islamic Jihad, the Popular Front for the Liberation of Palestine-General Command and a number of Salafist militant groups, which mostly operate in Gaza. Political opposition parties face financial constraints. The parties in the PLO are supposed to receive financial support from the PA central budget, but this rarely happens in practice.
Political opposition also takes the form of student activism and the PA and Hamas security forces are known to monitor the activities of student activists. In January 2015, the PA arrested and interrogated a student activist for 13 days based on an anti-government comment that he posted on Facebook.
The DFAT report goes on to suggest that the risk of harm from Hamas for persons with a low level political profile is moderate.
Although Palestinian political parties are united in their opposition to Israeli occupation, this sense of solidarity does not apply to Palestinian internal politics, which is very divided and volatile. High-profile political opposition members face a moderate level of official discrimination from the PA in the West Bank or Hamas in Gaza and are at risk of harassment or violence, especially from Hamas or the Israeli authorities. Broadly speaking, low ranking or low profile political supporters face a lower risk, subject to the qualification outlined in 3.25 above.
However a February 2018 report by the UNHCR on Country of Origin Information on the Situation in the Gaza Strip, Including on Restrictions on Exit and Return sets out the circumstances in Gaza and suggests that the situation in Gaza is rapidly deteriorating and that Hamas arbitrarily arrests and detains civilians.
Humanitarian Situation
The already protracted humanitarian situation in the Gaza Strip deteriorated markedly in 2017 and into 2018. An estimated 1.6 million people, or 64 per cent of the Gaza Strip’s population, are reportedly in need of humanitarian assistance in Gaza Strip, with high needs across most sectors. With the Gaza Strip reportedly heavily dependent on humanitarian assistance and services, concerns have been expressed about the impact of predicted funding cuts in 2018 to the United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA) on the continued provision of vital health, education and food services.
Human Rights Situation
The human rights situation in the Gaza Strip is reported to be deteriorating. Residents of the Gaza Strip reportedly face a range of human rights violations and abuses, overwhelmingly as a result of Israeli practices affecting the Gaza Strip and violations at the hands of the Hamas authorities. According to reports, human rights violations and abuses take place mostly in a climate of impunity.
This chapter focuses on human rights abuses committed by the Hamas authorities and to some extent other non-state actors in the Gaza Strip against Palestinian inhabitants of the Gaza Strip. It does not cover violations of International Humanitarian Law (IHL) by these actors, nor violations of IHL and human rights law by the State of Israel. However, it should be noted that the UN have referred to the continued blockade and restrictions imposed by Israel on movement of people and goods in and out of the Gaza Strip as amounting to the “collective punishment” of the entire population. In addition, Israeli security forces reportedly continue to use excessive force, killing and injuring civilians on the border fence between the Gaza Strip and Israel as well as at sea.
The Hamas authorities reportedly subject civilians to a wide range of human rights violations, including harassment; arbitrary arrests and detentions, including incommunicado detentions and pro-longed pre-trial detention; torture and other forms of ill-treatment; and trials that fall short of international fair trial standards. Furthermore, the UN and human rights organizations have expressed concern over the use of the death penalty and the fact that trials, particularly those in military courts, did not appear to meet minimum fair trial standards. Executions are reportedly regularly carried out in violation of applicable international and Palestinian laws. Detention centres are reported to be overcrowded and with poor conditions, and in some instances the use of torture and ill-treatment reportedly resulted in deaths. (Perceived) critics and opponents of the Hamas authorities, including activists, (perceived) affiliates or sympathizers of rival political organizations,122 suspected collaborators, human rights defenders, and journalists, are reportedly particularly singled out for arbitrary arrest, detention and other violations. In some instances, individuals have reportedly also been targeted on account of their family members’ actions.
The Hamas authorities reportedly also restrict the rights to freedom of speech (including on the internet) and assembly, and have at times resorted to excessive force to disperse protests and arrested protesters and organizers. Organizations affiliated with Fatah as well as women’s rights groups reportedly face difficulties operating.
The Tribunal accepts the applicant’s oral evidence that her family is subject to surveillance by Hamas. The Tribunal also accepts the applicant’s oral evidence that in addition to monitoring, and detaining those with different political views, Hamas also engages in practices such as bussing their political opponents to border areas where civilians are at risk of being caught in the crossfire with Israeli border guards. The Tribunal accepts this evidence as the applicant recounted her oral evidence in a credible manner and her evidence accords with the country information as set out above. The Tribunal finds that the harm which the applicant fears is serious harm as described in s.91R of the Act.
The Tribunal finds that there exists a real chance that the applicant would face serious harm by reason of her political opinion if she were to return to Gaza. The Tribunal is satisfied that the applicant has a well-founded fear of persecution for a Convention reason should she return to Gaza.
DECISION
The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s.36(2)(a) of the Migration Act.
Irene O'Connell
Deputy Division Head