1717097 (Refugee)

1717097 (Refugee) [2022] AATA 3255 (4 August 2022)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  1717097
COUNTRY OF REFERENCE:                   China
MEMBER:Catherine Carney-Orsborn
DATE:4 August 2022
PLACE OF DECISION:  Sydney
DECISION:The Tribunal affirms the decision not to grant the applicant a protection visa.

Statement made on 04 August 2022 at 2:06pm
CATCHWORDS
REFUGEE – Protection visa – China – religion – Christian – underground church – arrested due to Christian publications – credibility – admitted to not being a Christian – no response to tribunal communication – non-attendance at hearing – decision under review affirmed
LEGISLATION
Migration Act 1958, ss 5, 36, 65, 499
CASES
MIEA v Guo & Anor (1997) 191 CLR 559
Nagalingam v MILGEA (1992) 38 FCR 191
Prasad v MIEA (1985) 6 FCR 155
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 (the Department) on 28 July 2017 to refuse to grant the applicant a protection visa under s.65 of the Migration Act 1958 (Cth) (the Act).
The applicant who claims to be a citizen of China, applied for the visa on 24 October 2016. The delegate refused to grant the visa on the basis that the applicant was not a member of a particular social group to which Australia owed protection obligations.
On 28 June 2022, the Tribunal wrote to the applicant advising that it had considered the material before it but was unable to make a favourable decision on that information alone.
The Tribunal invited the applicant to appear before it on 26 July 2022 at 10:00AM to give evidence and present arguments relating to the issues arising in his case. The letter informed the applicant that if he did not attend the scheduled hearing, the Tribunal may make a decision without taking any further action to allow or enable him to appear before it. On 4 July 2022 the hearing invitation was sent to the applicant using the email address provided in connection with the review.
Two SMS reminders were sent to the applicant on the 19 July 2022 and 25 July 2022.
The applicant did not attend the hearing at the scheduled date and time. Having reviewed the material before it, the Tribunal is satisfied that the applicant was properly invited to a hearing, the invitation was sent to the authorised recipient by email using the correct address, and there is no evidence to suggest that the email transmission was unsuccessful. No postponement of hearing has been sought. No satisfactory reason for the non-appearance has been given. Accordingly, the Tribunal has decided to proceed to make its decision on the evidence before it.
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, the Tribunal has 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
The issue in this case is whether the applicant is owed Australian protection obligations including complementary protection. For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
The Tribunal has before it the Department and the Tribunal files. The Department file contains application forms, copies of identification and travel documents for the applicant, copy of a foreign travel visa, a copy of the applicant’s statement of claims, and a copy of the delegate’s decision.
The Tribunal file contains the application form and a copy of the delegate’s decision.
The following information was provided by the applicant in the application forms. He is from the Shanxi province and a fluent speaker, reader and writer of the Mandarin language. He has previously travelled to [a named country], Australia, and [Country 1] on holidays. In his home country, the applicant worked as [an Occupation 1].
The applicant claims that if he returned to his home country, he would be persecuted by the police who interrupted his once peaceful life.
The applicant submitted to the Department a statement of claims.
In his statement, the applicant said he learnt about the Christian faith through his mother when he was a child. She was a devoted Christian and so the applicant decided to become a Christian. The applicant attended an unregistered Christian church, the small ‘church’ meetings took place at people’s homes who took turns in hosting the ‘church’ meetings. The applicant stated that eventually his mother migrated to [Country 2] under a family reunion visa to live there with the applicant’s older sister. The applicant applied on numerous times for a [Country 2] visa but was unsuccessful.
In 2009, the applicant met his now wife. They got married in 2014; they together travelled to Australia and [Country 1] for their honeymoon. While being in these countries, the applicant visited the churches, and gathered from them booklets and brochures to take back to China and distribute amongst his Christian brothers.
The applicant stated that after he and his wife returned to China, they were attending a house church.
In or about June 2016, the police arrived at the house church, they discovered at the meeting place the Christian materials the applicant had brought from Australia, and he admitted to the police he had obtained them. The police detained everyone present for 15 days and forced the Christians to stand still for hours and periodically starved them as punishment, ostensibly for not providing more information about other adherents.
After 15 days everyone was released after they were made to sign a statement that they would not be affiliated with the Christian ‘cult' in the future. The police indicated that if any of the detainees disagreed with this statement, and/or were discovered practising Christianity again, they would be detained again for a longer period of time.
Following his release, the applicant was sacked from his job as [an Occupation 1] because his boss knew he had been detained for being a Christian and did not want him preaching to customers.
The Protection visa interview
On 24 July 2017, the Department held a protection visa interview with the applicant. At the interview, the applicant confirmed that he had studied politics at middle and high school, and Mao Zedong Theory in extracurricular lessons after school. He was also a member of the Communist Youth League when he was attending middle and high school.
The applicant confirmed that in general he supports the Chinese Communist Party and also the Chinese Government, although, he does not agree with some aspects of what the government has done.
The applicant indicated that he came to Australia because he wants to live here permanently and in order to work. He wants to live permanently in Australia because the environment is better, by which he meant both the physical and social environment, as well as the air quality and food are also better in Australia than in China.
When asked why he had applied for a protection visa, the applicant responded that he had asked around in the Chinese community and was advised that newcomers to Australia always apply for protection visas. When asked, he confirmed that he had applied for a protection visa because he wanted to gain permanent residence and live in Australia; he did not have any other reasons.
When asked about his religion and religious history, the applicant indicated that he was an evangelical Christian, that he converted to Christianity as an adult sometime after 2000, but before he married in 2014. He was also baptised, but he could not pinpoint the date of either his conversion or his baptism.
When put to the applicant that his conversion to Christianity was therefore not a particularly important event for him, he described it as just so-so.
When asked for his religious beliefs, what his religion meant to him, what he could tell about his religion, and how he would describe it to someone who knew nothing about it, the applicant responded that his belief was to be nice to other people, lead a simple life, and truthfulness is very important.
Based on the applicant's responses concerning his religious beliefs, what his religion meant to him, what he could tell about his religion, and how he would describe it to someone who knew nothing about it, the delegate put to the applicant that the delegate was not satisfied that he was a committed, genuine, or practising Christian, as he did not demonstrate any knowledge of Christianity (in particular he made no mention of either Jesus or God in his responses). When pressed on this point at the end of the interview, the applicant admitted that he was not a Christian.
When asked what booklets and brochures he had taken back to China in 2014, the applicant responded that it was some booklets handed out by Chinese people in the street. When asked what exactly, he was unable to remember and/or did not know.
The delegate refused to grant a protection visa to the applicant on 28 July 2017. On 5 August 2017, the applicant applied for review of the delegate’s refusal with the Tribunal.
Nationality
The applicant claims to be a citizen of China and has provided to the Department a copy of his Chinese passport. In the absence of any evidence to the contrary, the Tribunal is satisfied that the applicant is a citizen of China. The Tribunal finds that China is his receiving country for the purpose of assessing his claims for protection. There is no evidence before the Tribunal to suggest that the applicant has the right to enter and reside in any other country for the purposes of the Act.
Does the applicant have a well-founded fear of persecution?
The mere fact that a person claims a fear of persecution for a particular reason does not establish the genuineness of the asserted fear or that it is well founded. It remains for the applicant to satisfy the Tribunal that all of the statutory elements are made out. 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 himself in as much detail as is necessary to enable the Tribunal to establish the relevant facts. The Tribunal is not required to make the applicant's case for him. Nor is the Tribunal required to accept uncritically any and all of the allegations made by an applicant. (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 this case the applicant has made claims in his written visa application and oral evidence. He attended the interview with the delegate, as recorded in the delegate’s decision record, provided to the Tribunal by the applicant. As recorded in the decision record he stated he was a member of the Communist Youth League, He indicated that he came to Australia because he wants to live her permanently and in order to work. He stated that “he applied for a protection visa as he had asked around in the Chinese community and was advised that newcomers to Australia always apply for protection visas. He confirmed to the delegate that he applied for a protection visa to gain permanent residency and live in Australia, “he did not have any other reasons”.
The delegate discussed the applicant’s claims in relation to being a Christian. He claimed he was Christian and had converted to Christianity. He was baptised but could not give details of his conversion or baptism. He was unable to discuss his claim that he handed out brochures or booklets on Christianity in China. The delegate recorded that there were inconsistencies in his evidence and formed the view he lacked basic knowledge about Jesus and Christianity. At interview with the delegate, he stated he was not a Christian. The delegate was not satisfied he is a genuine Christian. The delegate was not satisfied that he was of adverse interest to the authorities, or that he was being monitored, as he was able to depart China legally.
The Tribunal wished to discuss these concerns with the applicant at the hearing, but he did not attend. The Tribunal has been unable to obtain further details about his claims, or to test their veracity. Had he attended the hearing it would have asked him further questions about each of his claims, and why he now fears returning to China.
On the basis of the evidence before it, the Tribunal is not satisfied the applicant was attending an underground house church meeting in June 2016 when the police attended and arrested those present. The Tribunal does not accept he lost his job in China due to being a Christian. The Tribunal does not accept he was distributing booklets and brochures about Christianity in China. It has difficulty accepting these claims because, as recorded by the delegate, his oral evidence on these issues was that he was not a Christian. It therefore does not accept he was detained or tortured by the police because it is not satisfied, he ever attended Christian gatherings or meetings. Given the information outlined in the delegates decision, of the oral evidence provided by the applicant at the protection interview, the Tribunal, is of the view that if the applicant was of adverse interest to the authorities, he would not have been able to depart China lawfully.
On the evidence before it, the Tribunal is not satisfied the applicant was brought up in a Christian family or that he has attended Christian Churches in Australia. It does not have any evidence about his current Christian practice and, given its concerns about his claims, is not satisfied he is currently practising Christianity in Australia.
The Tribunal is not satisfied the applicant has practised as an underground Christian in China. It is not satisfied he has practised as a genuine Christian while in Australia in 2014 or 2016. Nor is it satisfied he will practise as a genuine, committed Christian if he returns to China.
On the basis of these findings, the Tribunal is not satisfied the applicant has suffered any harm incurred by the authorities on the basis of his religious practice. Nor is it satisfied he fears his life will be damaged by the authorities if he returns to China.
The Tribunal has considered all of the material before it. It is of the view the applicant has merely made written and oral assertions to fear harm in China. The Tribunal is not satisfied there is any reliable evidence to suggest the applicant has any reason to fear harm if he returns to China. It is not satisfied he or any member of his family will participate in any religious activity or any other conduct that will result in his detention or in harm. The evidence before the Tribunal is not sufficiently detailed and persuasive for the Tribunal to be satisfied the applicant, or any member of his family, has been or will be involved in any religious activity, or any other conduct, that would result in the applicant coming to the attention of the authorities. It is not satisfied the applicant fears harm in China because of his religion or for any other reason.
On the evidence before it, the Tribunal is not satisfied that the applicant has a well-founded fear of persecution for reasons of his religion or for any other reason set out in the Act, or that there is a real chance that he would be persecuted for one or more of those reasons, and the real chance of persecution relates to all areas of China. Therefore, he does not meet the definition of refugee. Accordingly, the Tribunal is not satisfied the applicant is a person in respect of whom Australia has protection obligations under s.36(2)(a) of the Act.
Does the applicant meet the complementary protection criteria?
As the Tribunal has found that the applicant does not meet the refugee criterion in s.36(2)(a) of the Act, it has considered whether he may nevertheless meet the criterion for the grant of a protection visa under the complementary protection criterion.
As indicated above, the applicant has failed to provide sufficient details regarding his claims. As the applicant failed to attend his hearing, the Tribunal has been unable to obtain further information about his claims, or to test their veracity. In view of the above findings and on the evidence before it, the Tribunal is not satisfied that the applicant suffered harm in China or that there is a real risk that he will suffer significant harm if he returns to China.
On the evidence before it, the Tribunal is not satisfied that there are substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to China, there is a real risk that he will suffer significant harm. Therefore, the Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s.36(2)(aa) of the Act.

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.
Catherine Carney-Orsborn
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.
…
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.
…

[2022] AATA 3255

4 August 2022

Key Legal Topics

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Immigration

Administrative Law

Statutory Interpretation

Legal Concepts

Judicial Review

Jurisdiction

Procedural Fairness

Natural Justice

Statutory Construction

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