1725555 (Refugee)

1725555 (Refugee) [2022] AATA 2174 (30 May 2022)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  1725555
COUNTRY OF REFERENCE:                   Pakistan
MEMBER:Scott Clarey
DATE:30 May 2022
PLACE OF DECISION:  Melbourne
DECISION:The Tribunal remits the matter for reconsideration with the following directions:
(i)that the first named applicant satisfies s 36(2)(a) of the Migration Act; and
(ii)that the other applicants satisfy s 36(2)(b)(i) of the Migration Act, on the basis of membership of the same family unit as the first named applicant.

Statement made on 30 May 2022 at 2:17pm

CATCHWORDS
REFUGEE – protection visa – Pakistan – fear of harm from husband’s family – mother of daughters but no son – progressive physical, mental and emotional abuse – pressure on husband to divorce and remarry – members of family unit – third daughter born in Australia – consistent and credible claims and evidence – country information – cultural preference for sons, and gender-based violence and killings – political and socio-economic instability – no effective state protection and relocation not reasonable – decision under review remitted
LEGISLATION
Migration Act 1958 (Cth), ss 5J, 5LA, 36, 65
Migration Regulations 1994 (Cth), Schedule 2
CASES
Randhawa v MILGEA (1994) 52 FCR 437
SZATV v MIAC (2007) 233 CLR 18

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 Home Affairs on 6 October 2017 to refuse to grant [the applicant], a citizen of Pakistan, a protection visa under s 65 of the Migration Act 1958 (the Act). The delegate refused to grant the visa on the basis that they were not satisfied the applicant was owed protection in Australia. On 19 October 2017, [the applicant] applied to the Tribunal for review of this decision. She provided the Tribunal with a copy of the delegate’s decision record.
I note that in its decision record, the delegate stated the following:
Having considered the above country information, I accept there is a real chance the applicant would be persecuted by her in-laws if she returned to the Hafizabad area of Punjab. Having considered the country information outlined above, I also find the authorities would not be able to offer effective protection to the applicant. However, I do not find the real chance of persecution extends to all parts of Pakistan.
[The applicant] appeared before the Tribunal in Melbourne on 4 May 2022 to give evidence and present arguments. [The applicant] was represented [at] the hearing. The Tribunal hearing was conducted with the assistance of an interpreter in the Urdu and English languages.
The applicant in this case is a [Age]-year-old woman from Pakistan, who is the mother of three young daughters. Her claims for protection centre around the issue of her not having produced a male heir, something that is highly coveted in her family’s culture. She claims that her in-laws in Pakistan want her husband to remarry so that he may have a son with another woman and the applicant stands in the way of this happening. As a consequence, the applicant claims to fear family violence from her husband’s family in Pakistan. She claims that she and her daughters risk becoming the victims of a so-called ‘honour killing’ if she were to return there. The dispositive issues for determination in this case include whether the applicant’s claimed fear of harm from her husband’s family is credible and, if so, whether these fears would amount to serious harm for one or more of the five reasons set out in s 5J(1) of the Act. If the Tribunal finds that the applicant does not have a well-founded fear of persecution, it must also determine whether there are substantial grounds for believing that there is a real risk she will suffer significant harm, as a necessary and foreseeable consequence of her being removed from Australia to her receiving country of Pakistan.
[The applicant] is a Pakistani national born in Hafizabad, Punjab Province, Pakistan on [Date]. I accept that she is a Sunni Muslim and a member of the Punjabi ethnic group. She arrived in Australia on a student visa to pursue study and has enrolled in several courses of study since arriving in Australia. [The applicant] was married to [Mr A] (a second named applicant to this application) [in] March 2007 in Pakistan. I accept that she and her husband are the parents of three daughters (all of whom are second named applicants to this application). I note that her youngest daughter, [Child 3], was born on [Date] in Melbourne. [The applicant] is one of five siblings, with two sisters residing in Pakistan, one sister in Australia, one brother in Pakistan and one brother residing in [Country]. Her father is deceased, and her mother is currently residing in Pakistan.
[The applicant] first arrived in Australia [in] September 2011 with her family on a student visa (Subclass TU-572) granted to her on 17 June 2011, valid until 15 March 2014. She first departed Australia once in 2012 and once in 2013, returning [in] June 2013. [The applicant] again departed Australia [in] March 2016 returning [in] May 2016, holding a student visa. On 3 November 2016, she lodged the protection visa application that is the subject of this review and was granted an associated bridging visa.
On the basis of the copy of [the applicant]’s passport provided to the Department, I accept that she is a citizen of Pakistan and that her identity is as she claims it to be. I accept that Pakistan is [the applicant]’s country of nationality for the purposes of the refugee assessment and the receiving country for the purposes of the complementary protection assessment.
The issues in this review are whether [the applicant] has a well-founded fear of being persecuted for one or more of the five reasons set out in s 5J(1) of the Act and if not, whether there are substantial grounds for believing that, as a necessary and foreseeable consequence of her being removed from Australia to her receiving country of Pakistan, there is a real risk she will suffer significant harm.
For the following reasons, the Tribunal has concluded that the matter should be remitted for reconsideration.
Claims and evidence
Evidence before the Department
[The applicant] set out her claims for protection in her protection visa application form as follows:
Q88:     I am seeking protection in Australia so that I do not have to return to:
A:PAKISTAN
Q89:     Why did you leave that country/those countries?
A:I came here in Australia five years ago with my family in September 2011. I didn’t come here illegal arrivals, illegal maritime arrivals or unauthorised Air arrivals. Currently, I am on a Visa 572. Basically, I am primary applicant and been studying in different courses through the five years. That is the only one safe and legal way to came here at that time. Australia is always one step ahead in every field of life. Education and Health measures are the main stream, fundamentals rights for all, justice is done for the all equally. There is no other country like Australia on the globe.
In 2010 there were some family disputes in accordance domestic violence. When I gave birth to my second baby girl, my in-laws didn’t accept my second daughter. After that every single day had become worse and worse due to my new born baby. I was apprehending that one day, I will be die or my daughters also.
PLEASE REFER TO MY STAT DEC FOR MORE INFO
Q90:What do you think will happen to you if you return to that country(s)?
A:Harm/mistreatment always be there. During these years I went back two times to my country (Pakistan), harms/mistreat not only for me even is subject to my family as well. I have seen the consequences if I go back. I faced a lot of humiliation, bullying, mental torture from my in-laws the main reason is that I having daughters no boys. I am living here from five years. I am feeling free, safe and sound here. No other country like Australia in matter of health, education, fundamental rights. The question is that how will the life, if I go back to the Pakistan with my family. My husband is bound to divorce me otherwise death is certain for both of us along with children. We are so scared after getting life threats. My husband’s mother passed away and after that my father in-law got married; my husband’s step mother and father in-law both will not accept me and my daughters in their house. My family already refused me and my daughters to give shelter. The life of a single mom living with 3 kids in Pakistan is always full with risks like sexually assault, kidnapping of baby girls for sex trade, racial abuse and constantly bullying by society on daily basis.
Safety concerns so many as I mentioned above. My in laws can Mistreat and disregard family and myself. They will not be hesitate to any loss, even the life loss my and family. Living there with my family as my all children are Girls very difficult to look after them, for study, health safety, sports, even not more here and there freely. Always the shadows, clouds of fear and kill threats will be over our heads. One most important and heinous issue is the sexual harassment, no one even the single parent of the world don’t want to face the issue like sexual harassment, and will not be bear. If I go back I am sure I treat the Issues which I described in the statement. PLEASE REFER TO MY STAT DEC FOR MORE INFO.
Q91:     Did you experience harm in that country/those countries?
A:I always been a victim of mistreatment, mental and physical torture. A lot of time i be beaten by my father-in-law, mother-in-law and sisters in law after the birth of my second baby girl. They wanted boy not girl. After going through all this now I became a patient of siciatica during torture they tried to abored my third child and my back get effected badly.
Q92:     Did you seek help within the country/those countries after the harm?
A:No because i used to live there was no center of orgnaisation to help ladies in social issues. There is only one concept comprise of any situation where i should go with my daughters without support and guidance I seek help as well there is no concept to seek help except that cut the rights and lives this is the bitter reality.
Q93:Did you move, or try to move, to another part of that country/those countries to seek safety?
A:I won’t move or even try to move, reason was that my in-laws house worse and my other part of country more worst. Mostly i used to live my parents house after sometime or period situation get worst situation and crime ralio everywhere. Same like robbery, bombing, kidnapping and child rape. I was and will be thankful God and is great must Govt who provide shelter and protection in me and family.
Q94:Do you think you will be harmed or mistreated if you return to that country(s)?
A:Yes as i mentioned that they are not ready I accept me with my three daughters. My in-laws will be responsible for this harm that I feared it I go back my husband will divorce me and will marry with other woman for like sake of boy. second if I don’t give permission my husband for and marriage and he supports me and my daughters then our lives will be in danger. They can burn me. poison me and my kids to get rid.
Q95:Do you think the authorities of that country/those countries can and will protect you if you go back?
A:as all the countries aware bout the situation of third world countries. Pakistan is one example of this. Govt is very corruptive, no organisation or institute work for the betterment of people. Nothing is fair for commons. I don’t think that they can protect we and my daughter in this corruptive system neither today nor tomorrow.
Q96:Do you think you would be able to relocate within that country(s)?
A:I won’t be able to relocate in any part of the country. I will be the single mother with 3 daughters as I mentioned in my STATE DEC. If i go back my husbands 2^nd marriage is confirmed and my divorce as well. My parent can’t protect and afford we financial problems are big hurdle in relocation in other parts. I will every necessity of live in education and look after them.
Evidence before the Tribunal
In addition to a comprehensive legal submission (dated 27 April 2022), I note that a significant amount of new information was provided to the Tribunal by [the applicant]’s representative in the week leading up to the Tribunal hearing on 26 April 2022. I note that this evidence included new information that had not previously been provided to the Tribunal or the Department.
I note that in her legal submission (dated 27 April 2022), the applicant’s representative stated the following in relation to her client’s claims:
The Applicant’s fear is due to her being a member of a particular social group, that being a woman in Pakistan. Women can be classified as particular social group for the Convention reasons,35 as they share an innate characteristic or common background that cannot be changed or share a characteristic or belief that is so fundamental to their identity or conscience that should not be forced to renounce it and have a distinct identity which is perceived as being different by surrounding society. The Applicant believes that she will face serious harm because of her gender, namely being a woman, and her inability to produce a son.
…
We submit that the Primary Applicant will suffer significant physical harassment and significant physical ill-treatment if she is returned to Pakistan as set out in ss5J (5) and 91R(2) of the Act. The Primary Applicant has suffered physical and mental abuse at the hands of her in-laws due to her perceived failure to produce a son, and she will face further abuse and possibly death if she is returned to Pakistan. When it became known that the Primary Applicant was pregnant with her third daughter, her in-laws became physically and verbally abusive, and beat her on two separate occasions. The Applicant has suffered physical abuse including assaults and beatings, as well as constant verbal harassment, ill-treatment, and degrading treatment. The Primary Applicant’s in-laws have actively tried to separate the family by continuously pressuring the Primary Applicant’s husband to remarry to produce sons. This has impacted the Primary Applicant’s overall wellbeing, and she is fearful of returning to her home country because she will be subject to further mistreatment, assaults, and ongoing abuse by her in-laws. In addition, she is becoming increasingly concerned for the future of her three daughters.
I note that in a signed medical certificate (dated 20 April 2016), [a named doctor] stated:
It is here by certified that the under signed treated [the applicant] w/o [Mr A] while she was in pregnancy. I found various signs and symbol of torture on her body and her back bone has senously effective on inquiry her the history of her ailment before starting treatment she told that her in laws i.e her father in law, brother and sister in law torture her for the pregnancy of her third girl baby in her womb. That due to these harsh treatment her health and pregnancy is at stake.
At the Tribunal hearing on 4 May 2022, I discussed at length with [the applicant] various aspects of her claims and specific details of the issues she claimed to have faced in Pakistan. I note that [the applicant] gave oral evidence that was highly consistent with her previous accounts of these claims and issues, and the written submissions that have been made on her behalf.
At the hearing, [the applicant] stated that she was born in Hafizabad, in the Punjab region of Pakistan. She has four siblings, one older brother and sister and one younger brother and sister. She stated that her father passed away when she was a teenager. Her mother is still alive and lives in Pakistan. [The applicant] stated that she finished high school in Pakistan and completed tertiary studies, graduating with a Bachelor [degree]. She previously held jobs in Pakistan [doing a job task]. [The applicant] stated that she is a follower of the Sunni Muslim and stated that her ethnicity is Punjabi Urdu. When I asked [the applicant] why she had decided to leave Pakistan and come to Australia, she stated that she had wanted to further her education here and had enrolled in a certificate III in [Subject 2] and went on to complete a diploma in that subject area. She said in 2015 she extended her student visa and went on to study [Subject 3] before studying a course in [Subject 4]. [The applicant] later worked in [Work sector]. Her husband, [Mr A], works as [an Occupation] for [an employer] in Melbourne.
I asked [the applicant] what she feared if she were to return to Pakistan in the foreseeable future. She stated that she would definitely be in danger from her in-laws because she has three daughters and has not produced a son. She explained that her culture, community, and in particular her husband’s family, are extremely patriarchal and male dominated. She explained that having a male child is not only a source of pride for the family, but a means of furthering the family’s name and bloodline. A high degree of importance is placed on a male heir within families. When asked why such a premium was placed upon male heirs, she said that their thinking was that daughters was seen as a burden on the family and that their son (her husband) would need to put aside significant funds and assets for their dowries when they were married. She said they feared his whole life would be devoted to this pursuit and they considered that she had brought dishonour on the family by only producing daughters and not producing a son. When I asked [the applicant] when she had become aware of her in-laws’ hostility toward her, she said that each time she produced a daughter, their attitude worsened. She said taunts and verbal abuse had progressed to threats and ultimately physical violence.
I discussed with [the applicant] in detail incidents that she claimed occurred during a trip back to Pakistan in March 2016 while she was pregnant with her third daughter. [The applicant] stated that one of her daughters was diagnosed with a serious [health] condition that required treatment. [The applicant] said that due to long wait times in Melbourne for this treatment she had decided to return to Pakistan so that her daughter could be treated quicker there, by a family friend who was [a] doctor. [The applicant] and her daughter returned to Karachi for this treatment and stayed with her mother. She said that she deliberately avoided contacting or meeting her in-laws because she was aware of the acrimony between them related to the issue surrounding her not having a son.
[The applicant] said that her daughter underwent the surgery in Karachi but that the follow-up treatment was carried out in her hometown of Hafizabad. [The applicant] said that her in-laws (including her father-in-law, his elder sister and daughter, and a family friend) found out that she was in town and confronted her at the doctors’ surgery. [The applicant] said that her in-laws had become aware that she was pregnant with her third daughter, via her mother in Karachi, and were incensed because they had been hoping for a son and believed this was their last chance for [the applicant] to give birth to one. She said that she was physically assaulted by her in-laws, including having her hair pulled, being beaten and pushed to the ground, and sustained a significant back injury as a result of the attack. She said that she was told to either abort the baby or divorce her husband so that he can remarry. She said that her in-laws inquired with the doctor at the surgery about conducting the abortion. [The applicant] stated that the incident caused such a scene that various bystanders gathered around to watch. She said that after the incident was over, her doctor, who had witnessed the whole incident, had advised her to take her daughter and find a place where she would be safe from her in-laws.

I asked [the applicant] when she had become aware of her in-laws’ hostility towards her. She stated that her relations with her in-laws had always been frosty, but had gradually and continually soured as she gave birth to each successive daughter. She said she initially had a sense of hope that these relations could improve but that over time their attitude toward her had worsened. She was continually the target of their taunts and verbal abuse, including being called ‘cursed’ because she did not give birth to a boy. She said the reason they held these views about girl children was that they saw them as a burden on the family. They feared her husband would need to set aside most of his family assets to cover future dowries for when his daughters eventually married. She said that her in-laws believed she had brought dishonour on the family by not bearing a male child. She said they saw sons as a source of honour for the family and conversely daughters brought shame. She said that sons were able to carry on the family name and legacy and they were seen as sources of future support for the broader family, including their capacity to contribute financially.
[The applicant] stated that after the violent incident in Pakistan in 2016 she realised she would never be accepted by her in-laws and that their level of hostility had progressed into a hatred for her and her children. She said it was at this point that she realised her physical safety was in jeopardy, as was that of her daughters, and that she needed to take steps to ensure their safety. She said that she returned home to Australia and told her husband of what had happened and they had mutually decided that a protection visa application was the right path forward to protect her and her daughters from her husband’s family.
I asked [the applicant] what she feared if she was to return home to Pakistan in the foreseeable future. She said that she feared for her physical safety, and that of her daughters, because the animosity from her in-laws had reached such a high level. She said that she feared she would again be physically attacked, and that she would be the target of their ire because it was her who stood in the way of what they desired, which was her husband becoming the father of a male child and heir. She said that she feared that her in-laws could kill her to free her husband to pursue another relationship with a woman who may bear him a male child. She said that she doubted she could ever hide from her in-laws anywhere in Pakistan and be safe from them because of all of their family connections and relationships, it would be next to impossible for her family to conceal their whereabouts. [The applicant] said that she was very fearful of what would happen to her daughters if something happened to her.
In response to a similar question, [the applicant]’s husband [Mr A], stated that he thought murder of his wife by his relatives was a real possibility if the family were to return to Pakistan. He said that they may try and harm his children and that he would be coerced and even kidnapped by his family so that he would leave his wife and family behind, and pursue a relationship with another woman who may be able to bear him a male child. [Mr A] stated that his younger brother and father were associated with people who were involved with crime in Pakistan and that he feared they may seek to involve these associates in the commissioning of a crime against his wife. He said that in Pakistan it was very easy to pay criminals money to carry out acts of this nature.
RELEVANT LAW
The criteria for a protection visa are set out in s 36 of the Act and Schedule 2 to the Migration Regulations 1994 (Cth). 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.
Refugee criterion
Section 36(2)(a) provides that a criterion for a protection visa is that the applicant for the visa is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations 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.
Complementary protection criterion
If a person is found not to meet the refugee criterion in s 36(2)(a), he or she may nevertheless meet the criteria for the grant of 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 (DFAT) expressly for protection status determination purposes, to the extent that they are relevant to the decision under consideration.
Relevant country information
I note the following relevant information regarding the plight and treatment of women in Pakistan, drawn from the updated DFAT Country Information Report published on 25 January 2022:[1]
[1] DFAT Country Information Report, Pakistan, 25 January 2022, sections 2.89–2.100
Pakistan has one of the worst records for gender equality in the world. According to the World Economic Forum’s 2021 Global Gender Gap Report, Pakistan ranked 153 out of 156 countries for female economic participation and opportunity, educational attainment, health and survival, and political empowerment.
Article 25 (2) of the Constitution prohibits ‘discrimination on the basis of sex,’ subject to a caveat enabling the state to make laws to ’protect women and children.’ Nevertheless, discriminatory laws exist: a man can legally seek a divorce at any time, while a woman cannot; the legal marriage age for men is 18, while for women it is 16 (except in Sindh where it is 18); and marital rape is not criminalised.
There has been significant legislative progress on women’s rights at the provincial and federal levels in recent years. Laws against domestic violence in Punjab, Sindh, Balochistan and Khyber Pakhtunkhwa, as well as federal laws, have been introduced that criminalise honour killings and acid attacks. The enforcement and effectiveness of these laws varies. Some, such as the acid attack law, have been very effective: once common, acid attacks have decreased by about 80 per cent since 2014, according to in-country sources.
Women’s participation in society in Pakistan can be heavily curtailed depending on their social circumstances. Observation of the purdah (literally ‘curtain’, an Islamic practice of segregating women from unrelated men) restricts many women’s personal, social and economic activities outside the home. While women in cities such as Lahore, Karachi and Islamabad often enjoy relative freedom, conservative rural communities are much stricter. There are reports of widespread sexual harassment of women and girls in public places, schools and universities. Some, mostly wealthy, Pakistani women have attained senior positions in public life, but their experience is not representative of the general population.
Rates of gender-based violence are high. The Pakistan Demographic and Health Survey 2017-18 found 27.6 per cent of ever-partnered women aged 15-49 had experienced physical violence, mostly at the hands of their husbands. NGOs claim the actual prevalence is much higher. NGOs and government officials report domestic violence has risen sharply during COVID-19.
Gender-based violence often goes unreported due to stigma and a lack of privacy for victims, even when they are wealthy and well-connected. Victims of rape often avoid reporting for fear they will be blamed or killed for ‘dishonouring’ their family, and because attending police stations may put them at risk of further violence. Extremely low conviction rates also discourage reporting of rape and other forms of GBV, as does a lack of female police officers. Domestic violence is commonly seen as a private family issue, and police are often reluctant to intervene. Federal and provincial governments have tried to improve official responses to gender-based violence, including through establishing GBV courts and women’s police stations, available in some major cities. In May 2021, police opened a Gender Protection Unit with a 24- hour hotline in Islamabad, which handled more than 500 complaints in its first three months.
Without support it is extremely difficult for a woman to relocate to escape an abusive relationship. Women who leave their families face physical risk, stigma and steep economic barriers. State-run women’s DFAT Country Information Report – PAKISTAN - January 2022 32 shelters (darul aman) require a court order to enter and leave, and are described as having ‘prison-like’ conditions. Private and NGO-run shelters exist, but they are unable to meet demand. Families often pressure victims to return to their abusers; in some cases victims are lured into returning and are killed. In Punjab it is possible to obtain a restraining order under the Punjab Protection of Women against Violence Act, 2016. Elsewhere in Pakistan a judge may issue a ‘protection order’ (denial of bail) to protect any victim or witness of a crime, but these are rarely granted. 3.96 So-called ‘honour killings’, in which family members murder relatives perceived to have brought dishonour on the family, are common in Pakistan. Human Rights Watch estimates there are about 1,000 honour killings in Pakistan each year. Honour killings can be carried out in response to behaviour including refusing an arranged marriage, forming an unapproved romantic attachment, or ‘immodest’ dress or behaviour, including social media posts. While young men can be targets of honour killing, most victims are female. Once a threat of honour killing is established, the victim remains at risk even if he or she relocates. In some cases, victims have been killed years after the initial transgression. In tribal areas honour killings are sometimes ordered by traditional jirga councils (see Judiciary, Cruel, Inhuman and Degrading Treatment).
Forced and underage marriage is a widespread problem in Pakistan. Religious minorities are at particular risk (see Christians, Hindus). A frequently-quoted estimate is that about 1,000 forced marriages take place in Pakistan each year. While the marriage age for girls is technically 16, Islamic jurisprudence provides for girls to be married once they reach puberty. Girls as young as 12 have been abducted, raped, threatened with violence and, in some cases, forcibly converted to Islam. In tribal areas, forced marriages are sometimes ordered by traditional jirga councils under a custom known as badal-e-sulah, where girls and young women are given away to settle blood feuds or land disputes among men.
Female journalists, activists and opposition politicians are frequently subjected to online harassment, including threats of physical and sexual violence, on the basis of their sex. Women who participate in the annual Aurat (Women’s) March have been condemned for promoting ‘vulgar’ behaviour and threatened with violence. In 2020, doctored photos of women holding placards deemed insulting to Islam were circulated online, drawing threats and hate speech. See also NGOs, Media and Journalists.
Militant groups such as the TTP have attacked female teachers and school students due to their ideological opposition to female education. The 2012 shooting of prominent female education activist Malala Yousafzai while she was travelling on a school bus in Swat was a direct response to a series of media interviews in which she argued that girls had a right to education and condemned the TTP. Attacks on girls’ schools continue, particularly in the former FATA, Khyber Pakhtunkhwa and Balochistan. A significant attack occurred against 12 schools in Gilgit Baltistan in August 2018.
DFAT assesses that women and girls in Pakistan face a high level of official discrimination in the form of inadequate state protection from gender-based violence. Women also face significant legal discrimination on issues such as inheritance, property rights, family law, and civil and traditional judicial processes. DFAT assesses that women and girls in Pakistan face a high risk of societal discrimination and violence, particularly domestic violence, because of their sex. Poor, marginalised, minority, and rural women are particularly vulnerable and lack access to support services.
In her submission to the Tribunal (dated 27 April 2022), [the applicant]’s representative noted the following country information:
The UK Home Office report on women and gender violence notes that “domestic abuse, which can take the form of psychological, physical and combined physical/sexual abuse, is widespread and usually committed by husbands, fathers, brothers and in-laws”.[2] In the current matter, the primary Applicant’s in-laws want her to produce a son, as a son is seen as a more desirable gender, as they are able to carry on the family name and confer social value to the family. In a report by Population Council in July 2015 it was noted that there was evidence of son preference in Pakistan, with the report noting “The unhappiness and depression was attributed by respondents to pressure from in-laws and relatives who are displeased and behave poorly with women when they conceive a girl. It was mentioned that sometimes women are even divorced for bearing daughters”.[3]
[2] UK home Office, Country Policy and Information Note Pakistan: Women fearing gender-based violence, February 2020, 10, Available at:
[3] Zeba A. Sathar, Gul Rashida, Sabahat Hussain and Anushe Hassan, Evidence of Son Preference and Resulting Demographic and Health Outcomes in Pakistan, July 2015, 14
A woman came to me for a checkup and ultrasound. She already had three daughters and now again she had a female child. On hearing this, she started crying and said not to inform her in-laws about it because they would be angry and mistreat her. (Female, Gynaecologist, aged 58).[4]
A research paper on son preference in Pakistan found that:
Among Asians, particularly in the South-East, son preference is a matter of cultural trend as well socioeconomic dependency on sons; there is a candid bias towards sons especially in lower classes; not for girls as they are not considered socioeconomically as supportive. Rather, girls are considered liabilities for parents in form of requirement of arranging suitable husbands and hefty dowry. In Pakistan, parents of daughters are most worried because they have to arrange suitable marital proposals for them, and a girl’s marriage costs them decades’ savings, while sons become a source of getting dowry on their wedding. Further, there is a lack of social support provided by daughters in old age.[5]
In December 2016, in Vehari, Pakistan a woman poisoned her infant daughter and then committed suicide, after a quarrel with her mother-in-law regarding her inability to produce a son.[6] Further, a news report from February 2022, noted that a woman in Peshawar sought help from a healer after she learnt she was pregnant with her fourth daughter. The healer had hammered a nail into her head, reportedly advising her that the act would guarantee the birth of a son.[7] Although these actions are extreme, and we do not suggest that the Applicant would hurt her children, these actions show the prevalent and detrimental impact of son preference in Pakistan, felt not only by the Applicants.
…
In 2021, 128 women were killed in Sindh Province due to honour killings and in Punjab province, where the Applicant is from, “between July and December 2021, 90 women were killed, 2,439 were raped and 9,529 women were kidnapped”.[8] Human Rights Watch noted that in a “patriarchal culture like Pakistan’s, where domestic violence is rampant, it is not unusual for men to murder female relatives to punish behavior they deem unacceptable. In most reported cases, the harshest punishments on grounds of “honor” come from male- dominated jirgas, tribal and village councils”.[9] In March 2022, a man shot and killed his infant daughter due to his preference of having a son. A spokeswoman from National Commission on Status of Women said that “the sole purpose of killing the child was her gender”.[10] Although, the Applicant’s husband does not pose a risk to his wife or daughters, his family does. The death of this infant shows the prevailing son preference and honor killings in Pakistan which are a real and significant risk to the Applicants.[11]
It was noted that:
Pakistan’s societal preference is nothing new as the newborn girls in Pakistan often go missing. Scores of infants are left in white metal Edhi cradles and the more unfortunate ones either get tossed in the nearby trash dumps or are conveniently buried elsewhere, as per a report in the The Daily Times.[12]
[4] Ibid
[5] Atif K, Zia Ullah M, Afsheen A, Naqvi SAH, Raja ZA, Niazi SA. Son Preference in Pakistan; A Myth or Reality. Pak J Med Sci. 2016;32(4):994-998. doi: Rashid Javed and Mzhar Mughal, Son preference and within-household bargaining position of Pakistani women, 14 November 2019, available at: within-household-bargaining-position-of-pakistani-women-preference-pour-les-garcons-et-le-pouvoir-de- negociation-des-femmes-pakistanaises/
[7] Tanvi Akhauri, Nail Hammered Into Pregnant Pakistani Woman’s Head To Guarantee Birth Of Son: Report, 9 February 2022, available at: head/
[8] Sadiq Bhanbhro, Pakistan again faces questions over ‘honour’ killings as brother acquitted of social media star’s murder, The Conversation, 3 March 2022, available at: questions-over-honour-killings-as-brother-acquitted-of-social-media-stars-murder- 177174#:~:text=My%20analysis%20of%20the%20reports,in%20the%20name%20of%20honour
[9] Saroop Ijaz, Human Rights Watch, ‘Honor’ Killings Continue in Pakistan Despite New Law, 25 September 2017, available at:
[10] Saroop Ijaz, Human Rights Watch, ‘Honor’ Killings Continue in Pakistan Despite New Law, 25 September 2017, available at:
[11] Ibid
[12] Ibid

I also note very recent developments in Pakistan, including the highly volatile and fluid political situation that resulted in the ousting of Pakistan’s Prime Minister on 10 April 2022.[13] I note also that human rights groups, including Human Rights Watch, have voiced concerns that the political instability currently being experienced in Pakistan could result in increased violence and unrest throughout the country and noted several explicit threats of violence voiced by politicians.[14] I note also country information that highlights a surge in political violence including religiously motivated terrorism in recent weeks. For example, a suicide attack took place on 7 March 2022 at a cultural festival in Sibi, Balochistan, killing several members of a local police force, and a bomb was detonated at a Shia mosque in Peshawar on 4 March 2022. Country information suggests that this violence is evidence of a resurgence of militancy across the country that is seeking to take advantage of the political instability and leadership vacuum related to the recent political crisis.[15]
[13] BBC NEWS, ‘Imran Khan ousted as Pakistan’s PM after vote’, 11 April 2022. Available at:
[14] Patricia Gossman, ‘Pakistan’s No-Confidence Vote Should Respect Democratic Process’, Human rights Watch, 16 March 2022. Accessed at:
[15] The Associated Press, ‘Pakistan says 4 troops killed in attack claimed by Taliban’, 25 March 2022. Accessed at: and reasons
I accept that [the applicant] is a Pakistani Sunni Muslim woman, who was born and raised in Hafizabad, Punjab Province, on [Date]. I accept that she is married to [Mr A], and has three daughters ([Children 1-3]), the youngest of whom was born in Australia. I accept that [the applicant] is involved in a protracted and highly acrimonious dispute with her husband’s family, related to the issue of her not having produced a male heir, something that is highly coveted in her family’s culture. I accept that [the applicant] was violently assaulted by her in-laws as claimed during a trip home to Pakistan in 2016 when she was pregnant with her third daughter. I accept that [the applicant] holds a genuine fear of harm from her in-laws if she were to return to Pakistan in the foreseeable future. I accept that her fear of harm relates to her membership of a particular social group, namely that of being a Pakistani woman who is the mother of three daughters and who has not produced a male heir. I accept that [the applicant] fears that she and her daughters fears serious family/gender based violence, and that they may become the victims of a so-called ‘honour killing’ at the hands of her in-laws, because of their desire for her husband to remarry so that he can have a son with another woman.
As noted above, I found [the applicant] to be a highly credible witness. I note that [the applicant]’s oral evidence was highly consistent with her written claims and evidence. As outlined above, I discussed various issues and concerns with [the applicant] and her representative at the hearing and I’m satisfied with the responses provided. As noted above, the Departmental delegate, in its decision record of 6 October 2017, accepted that [the applicant] faced a real chance of persecution from her husband’s family if she returned to her home area in Pakistan and found that the Pakistani authorities would not be able to offer effective state protection.
Having considered the available country information and [the applicant]’s specific circumstances, particularly (as detailed above) the information relating to the situation facing women in Pakistan, I am satisfied that in these circumstances [the applicant] would face a real chance of serious harm from her husband’s family – and/or agents acting on their behalf – if she were to return to her home area for reasons relating to her membership of a particular social group, namely that of being a Pakistani woman who is the mother of three daughters and who has not produced a male heir, as required by s 5J(4)(b) of the Act, in that it would involve a threat to her life or liberty or significant physical harassment or ill‑treatment. I also consider that [the applicant]’s membership of this particular social group is the essential and significant reason for the persecution she fears, as required by s 5J(4)(a), and that the persecution which she fears involves systematic and discriminatory conduct, as required by s 5J(4)(c), in that it would be deliberate or intentional and involve her selective harassment.
Pursuant to s 5J(6), I am satisfied that the reasons [the applicant] faces a well-founded fear of persecution relate to behaviours and/or conduct that was not engaged in by [the applicant] in Australia for the purpose of strengthening her claim to be a refugee.
Relocation
In SZATV v MIAC (2007) 233 CLR 18, the High Court endorsed the proposition that a person will not be excluded from refugee status merely because he or she could have sought refuge in another part of the same country, if under all the circumstances it would not be reasonable to expect him or her to do so. The Court further held at [24] that what is reasonable, in the sense of practicable, must depend on the particular circumstances of the applicant and the impact upon that person of relocating within their country. As Kirby J stated at [97], the supposed possibility of relocation will not detract from a ‘well-founded fear of persecution’ where any such relocation would, in all the circumstances, be unreasonable.
I am satisfied that [the applicant], as a citizen of Pakistan, has the right to relocate within Pakistan. I note that the range of factors which may be relevant in any particular case to the question of whether relocation is reasonably available will be largely determined by the case sought to be made out by an applicant.[16]
[16] Randhawa v MILGEA (1994) 52 FCR 437 per Black CJ at [443]; per Whitlam J at [453]
In considering [the applicant]’s circumstances and the ‘reasonableness’ of her relocating within Pakistan, I have considered advice in the DFAT Country Information Report, and additional country information about the situation facing women in Pakistan and the current political and security situation in the country. I have also had regard to oral and written evidence provided by [the applicant] and her representative on this issue. I accept that because [the applicant]’s persecutors are close family members, this complicates the ability of her and her immediate family to safely relocate elsewhere in Pakistan. I note the following from the DFAT Country Information report on Pakistan:
Certain types of threats (such as honour killings) are persistent, and even if people relocate they can be tracked down and killed years later. DFAT assesses that groups facing official discrimination will face discrimination in all parts of the country
For these reasons, I do not consider it would be reasonable to expect [the applicant] and her immediate family to relocate themselves to another part of Pakistan to escape the real chance of serious harm she faces in her home area.
State protection
A person does not have a well-founded fear of persecution if effective protection measures are available to the person in a receiving country: s 5J(2). Section 5LA(1) provides that effective protection measures are available if protection against persecution could be provided to the person by either the relevant State, or a party or organisation (including an international organisation) that controls the relevant State or a substantial part of its territory, and that State, party or organisation is willing and able to offer such protection.
A relevant State, party or organisation is taken to be able to offer protection against persecution to a person if the person can access the protection, and the protection is durable and, in the case of protection by the relevant State, the protection consists of an appropriate criminal law, a reasonably effective police force and an impartial judicial system: s 5LA(2) of the Act. I have considered if effective protection measures are available to [the applicant] in Pakistan as required by s 5LA. The harm that [the applicant] fears is from her extended family members and/or agents acting on their behalf and she claims that the Pakistani authorities will not protect her or her family from that harm.
In her submission to the Tribunal (dated 7 April 2022), [the applicant]’s representative noted the following:
The Applicant is unable to seek protection from the police regarding gender-based violence, as the DFAT report notes that there is an “extremely low conviction rates” which also discourages women reporting gender-based violence.25 DFAT notes that women in Pakistan “face a high level of official discrimination in the form of inadequate state protection from gender-based violence”.[17] Further the US Department of State Human Rights Practises report on Pakistan from 2020, noted that in instances where women went to the police to report domestic violence or abuse that “instead of filing charges, police often responded by encouraging the parties to reconcile. Authorities routinely returned abused women to their abusive family members”.[18]
Further the UK Home Office report noted that:
Pakistan has a functioning criminal justice system; however, the authorities are sometimes unwilling to provide protection for women fearing sexual or gender-based violence as police and judges are reluctant to take action in domestic violence cases, viewing them as family problems. Instead of filing charges, police typically responded by encouraging the parties to reconcile and returning the victims to their abusers. It is common for police to refuse to register reports of rape. Some police demand bribes before registering cases and investigations are often superficial.[19]
[17] Department of Foreign Affairs and Trade, DFAT Country Information Report Pakistan, 25 January 2022, 31, Available at < US Department of State, 2020 Country Reports on Human Rights Practices: Pakistan”, 30 March 2021, 47, Available at < REPORT.pdf>
[19] UK home Office, Country Policy and Information Note Pakistan: Women fearing gender-based violence, February 2020, 12, Available at: < tan-Women-CPIN-v4.0_Feb_2020_.pdf>
Based on the available country information, I find that [the applicant] could not obtain, from an authority of the country, effective state protection against the harm she faces.
Conclusion on issues related to harm in the future from a family dispute
Considering [the applicant]’s particular circumstances cumulatively, and in the context of the relevant country information, I find that there is a real chance that she will suffer persecution involving serious harm, from her husband’s family and/or their agents, if she returned to her home in Hafizabad, Pakistan. I am satisfied that the real chance of serious harm [the applicant] will face if she returned to her home area in Hafizabad, Pakistan, will be a result of systematic and discriminatory conduct in that it will be done to her selectively and intentionally. I find that the essential and significant reason for the serious harm [the applicant] faces is due to her membership of a particular social group, namely as a Pakistani woman who is the mother of three daughters and who has not produced a male heir.
For the reasons given above, I am satisfied that [the applicant] is a person in respect of whom Australia has protection obligations. Therefore she satisfies the criterion set out in s 36(2)(a).
DECISION
The Tribunal remits the matter for reconsideration with the following directions:
(i) that the first named applicant satisfies s 36(2)(a) of the Migration Act; and
(ii)that the other applicants satisfy s 36(2)(b)(i) of the Migration Act, on the basis of membership of the same family unit as the first named applicant.
Scott Clarey
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.
…

tan-Women-CPIN-v4.0_Feb_2020_.pdf

[2022] AATA 2174

30 May 2022

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