1836828 (Migration)

1836828 (Migration) [2019] AATA 6589 (23 September 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER: 1836828
MEMBER:Margie Bourke
DATE:23 September 2019
PLACE OF DECISION: Melbourne
DECISION:The Tribunal affirms the decision not to grant the visa applicant a Return (Residence) (Class BB) visa.

Statement made on 23 September 2019 at 11:26am

CATCHWORDS
MIGRATION – Return (Residence) (Class BB) visa – Subclass 155 (Five Year Resident Return) – proposal to establish business not evidence of business ties to Australia – no evidence of employment or cultural ties with Australia of benefit to Australia – sibling relationship not evidence of personal ties to Australia – little time spent in Australia before application – no compelling and compassionate reasons – decision under review affirmed

LEGISLATION
Migration Act 1958 (Cth), s 65
Migration Regulations 1994 (Cth), Schedule 2, cl 155.212

Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 378 of the Migration Act 1958 and replaced with generic information.
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 23 October 2018 to refuse to grant the visa applicant (the applicant) a Return (Residence) (Class BB) visa under s.65 of the Migration Act 1958 (the Act).
The applicant applied for the visa on 23 May 2018. At the time of application, Class BB contained two subclasses – Subclass 155 (Five Year Resident Return) and Subclass 157 (Three Month Resident Return). In this case, claims have been advanced in respect of Subclass 155. The criteria for a Subclass 155 visa are set out in Part 155 of Schedule 2 to the Migration Regulations 1994 (the Regulations). Relevantly to this case, they include cl.155.212.
The delegate refused to grant the visa on the basis that the applicant did not meet cl.155.212 because the delegate was not satisfied that the visa applicant met any of the alternative requirements in (2), (3), (4) or (5) in this subclause.
The visa applicant is the review applicant in a matter involving a child dependent visa, which was constituted to me and listed for review on 9 September 2019. The review applicant’s representative in the second matter contacted the tribunal, to advise she acted in both matters, that this review in relation to the subclass 155 visa was relevant to the second matter, and should be determined first, or at the same time. Ultimately, the review applicants in both matters consented to the two matters being listed and conducted as a combined hearing. This was an appropriate course as issues relevant to both reviews were discussed in the hearing.
The review applicant in this review (the subclass 155 matter) [Mr A] appeared before the Tribunal on 9 September 2019 to give evidence and present arguments. The Tribunal also received oral evidence from the visa applicant [Mr B] and his wife [Ms B] by telephone from [Country 1]. [Mr B] is also the review applicant in the second review (the subclass 101 matter). The visa applicant [Master C] in that matter did not give evidence as he is a [young] child. The evidence of his circumstances and intentions in relation to the visa were provided by his parents. All adult parties were present, either in person, or via telephone, for the duration of the combined hearings.
The combined hearing was conducted with the assistance of an interpreter in the English and Tagalog languages. The interpreter was for the assistance of [Ms B]. Both [Mr B] and [Mr A] spoke English. I had to repeatedly ask [Mr B] to repeat his evidence more slowly as I had difficulty understanding his evidence due to a lack of clarity on the telephone connection and due to his accent. I am satisfied that all the evidence given was understood, and I acknowledge the witness displayed patience in repeating his answers.
The review applicant was represented in relation to the review by his registered migration agent.
For the following reasons, the Tribunal has concluded that the decision under review should be affirmed. As all parties in both hearings share the same surname, I have referred to them by their first name, or as the visa applicant and review applicant relevant to the subclass 155 visa review in this decision record.
CONSIDERATION OF CLAIMS AND EVIDENCE
The main issue in this case is whether the visa applicant has substantial business, cultural, employment or personal ties with Australia which are of benefit to Australia to satisfy cl.155.212(3).
Lawful presence/substantial ties
At the time of application, the applicant must meet one of the alternative requirements set out in cl.155.212. Subclause (1) requires that the visa applicant meet the requirements of subclause (2), (3), (3A) or (4). These requirements essentially relate to the visa applicant being lawfully present in Australia for a certain time before the visa application, having substantial ties with Australia or being a member of the family unit of a person who meets these requirements.
In this case, the visa applicant is seeking to meet cl.155.212(3). His representative submitted he did not meet the alternative requirements in cl.155.212(2), (3A) or (4). The visa applicant does not claim to meet any of the other subclauses in cl.155.212, but I will briefly assess whether the visa applicant meets these alternate criteria.
As the visa applicant was outside Australia at the time of application, the visa applicant cannot meet cl.155.212(3A). There is no evidence that the visa applicant is the member of a family unit of a person who has been granted a Subclass 155 visa, or who meets the requirements of subclauses (2), (3) or (3A) and has lodged a separate application for a subclass 155 visa, and therefore does not meet the requirements of cl.155.212(4). I find the visa applicant cannot meet cl.155.212(3A) or (4).
Was the applicant lawfully present in Australia?
Subclause 155.212(2) is met if the applicant was lawfully present in Australia for a total of not less than 2 years in the period of 5 years immediately before the visa application and, during that time was an Australian citizen or the holder of a permanent visa or permanent entry permit; and was not the holder of certain specified visas.
The visa applicant lodged the application online for the subclass 155 visa on 23 May 2018. In the Department decision record dated 23 October 2018, a copy of which was provided to the tribunal by the review applicant, the delegate recorded that the visa applicant had been present in Australia for a total of 21 days in the five years immediately before the time of application. The representative indicated at the commencement of the hearing that they accepted the visa applicant had not spent a total of not less than two years in the period of five years immediately before the visa application was made.
Based on the evidence before me I am satisfied that the visa applicant was not lawfully present in Australia for a total of two years in the five year period immediately before the visa application was made. Accordingly, I find the visa applicant does not meet cl.155.212(2).
Does the applicant meet the substantial ties criterion?
Subclause 155.212(3), as extracted in the attachment to this decision, requires that if the applicant is outside Australia at the time of application, the Tribunal must be satisfied that he or she has substantial business, cultural, employment or personal ties with Australia which are of benefit to Australia.
Additionally, the applicant must have a particular residency/citizenship status or history, and not have been absent from Australia for a prescribed period, unless there are compelling reasons for the absence.
Does the applicant have substantial business, cultural, employment or personal ties with Australia that are of benefit to Australia?
I have considered the work references from the director and [manager], and I accept that the visa applicant has been employed by the same [firm] in [Country 1] for the past 25 years as a [Occupation 1]. I accept the visa applicant is currently employed by the firm. The written evidence indicated the visa applicant intended to establish his own business based in Australia, trading primarily in Asia and Africa. I accept his evidence that he travels internationally in his current employment. , The oral evidence in the hearing is that he intends now to establish his own [business] based in Australia trading primarily in [Country 2] and [Country 3]. I accept the business is not established, and the visa applicant intends to set up [a] business.
It is relevant that the visa applicant does not have employment in Australia, and does not have settled business connections in Australia. I have considered his evidence that he registered a company in Australia but it is not operational. I have considered the visa applicant’s record of registered business name, [which] was registered [in] May 2017 with ASIC, and a copy of the registration was provided to the Department with his application for a subclass 155 visa applied for in May 2017. (The visa was granted on 13 July 2017 and the visa applicant was required to arrive prior to 13 July 2018.) I have considered his evidence that he has contacts established through his current employment, but that he is not currently in communication with the contacts in relation to his proposed business.
I have considered his evidence that at the time he applied for the child visa in 2016, the visa applicant did not have employment in Australia and intended to start his own business; his plan was to rent accommodation for a period until he saw what happened. His evidence is he now intends to purchase a property immediately and he is 100% confident he can establish [a] business of his own in Australia, trading [a range of products] to [Country 3] and [Country 2] at cheaper rates than competitors. I discussed the visa applicant’s change in his approach and attitude at this later time, and he reiterated his confidence in his business acumen.
The visa applicant stated he was in a position to bring approximately [amount range] in cash with him to Australia, and would be able to raise further equity estimated at up [to a larger amount of money] from the sale of property he owned in [Country 4] and property his wife owned in [Country 5]. It was submitted his financial contribution would be of benefit to Australia. The review applicant had provided the tribunal with printouts of enquiries into units for sale. I accept the visa applicant intends to work and manage his own business, and pay tax on any profits made.
I have considered the visa applicant’s evidence, and the documentary evidence provided in support. I accept the visa applicant is a valued and long time employee with relevant skills for his position. I accept the visa applicant has access to cash, to assist in setting up the business. (I note that the oral and written evidence indicated the funds would also go towards purchasing a home.) I accept the visa applicant intended to work with his current employer as a supplier as part of his proposed business.
However I do not consider the proposal to establish a business is evidence of business ties of benefit to Australia. The business is not established or active, and the visa applicant is not definite about the products he will [work with], but nominated a range of [certain] products. I note the products the visa applicant nominated to trade in his business are different to the [products] one of the references stated his current employer trades in, which is the source of the visa applicant’s 25 years of experience. There was no evidence what benefit the visa applicant’s proposed company will be for Australia in terms of employment or training prospects, nor was there evidence of what revenue or production or trade activity the proposed business will generate. The evidence of the visa applicant did not indicate any particular knowledge or research of Australian conditions or workplaces or trade markets. I have considered the evidence before me, and I am not satisfied that the visa applicant has business ties with Australia, or business ties which are of benefit to Australia.
There is no evidence that the visa applicant had employment ties with Australia which are of benefit to Australia. The visa applicant is currently employed in [Country 1] by a company that has no ties to Australia, and he states he will leave this employment if granted the visa.
There is no evidence that the visa applicant has any cultural ties which are of benefit to Australia. There is no evidence that the visa applicant is involved in traditional, religious, arts or sporting organisations or activities that would be of benefit to Australia.
The visa applicant claims he has personal ties to Australia. The visa applicant’s brother [Mr A], the review applicant, resides in Australia. The review applicant stated he came to Australia in the year 2000, and has been employed in full time work since his arrival. The review applicant’s and visa applicant’s aunt also resided in [City 1] but she died in 2018, and the review applicant stated he has felt the lack of family members since her death. I have considered the medical reports that record the review applicant was referred for psychological treatment, and placed on a mental health care plan in response to his [disorder] related to health stresses, particularly in relation to [Medical Condition 1]. The review applicant stated he had a little problem with his [specified], but felt everything was affecting him at once, which was why he consulted the doctor and had the psychiatric assessment. I note he was referred to a psychologist, not a psychiatrist but consider this of little relevance, the relevant information being the review applicant has consulted a specialist because of a decline in his mental health. I accept he is receiving treatment for a condition resulting from his [Medical Condition 1] and other factors. I accept the review applicant was referred to the [Named] Hospital for an appointment in relation to his [issue].
The review applicant stated that he had a close relationship with the visa applicant. The review applicant stated they travel to visit each other. When I discussed that [Mr B] had only been in Australia for a small number of days over the preceding years, and it did not seem like a close personal relationship demonstrated by visits, the review applicant stated they were both very busy and worked hard. He stated he was lonely and would like to have family members in Australia again. He stated that his brother and his family could live at his house until they arranged their own accommodation.
The review applicant stated that he and his brother communicated by telephone with [skype] more than once a week. He stated he was masterful with technology. He stated he and his brother did not need to meet face to face because they communicate on the best telephone technology. The visa applicant also stated that they communicate once or twice each week, and the clarity of communication and vision on WhatsApp exceeds other methods. (It was the tribunal that asked the review applicant if he used skype on his phone, I am satisfied there is no inconsistency here in the different names of the communication apps. I accept the review applicant and visa applicant use the same method of communication.) I accept the parties communicate regularly, and find this a satisfactory way of maintaining their relationship. I have noted and give weight to the review applicant’s opinion that he did not need to meet with his brother face to face. I have noted and give weight to the evidence of the review applicant that he has consistently travelled each year to visit his siblings.
I am satisfied that the review applicant and visa applicant have resided in different countries for 19 years. I am satisfied the review applicant travels overseas each year to visit his brother and his family in [Country 1] or his sister and her family in [Country 4]. I accept the review applicant has visited Australia for short visits and amounting to only a brief number of days over the last decade. Both [Mr B] and [Mr A] stated that [Mr B] had not visited Australia often, or spent much time in Australia. The visa applicant stated he had spent time in [Country 4] when his parents were not well.
I discussed with the parties in the combined hearing that [Mr B] had spent a total number of [specified] days in Australia in the ten years before the visa application for dependent child visa was made on 20 October 2016. This was calculated in the hearing by checking the movement records. The calculations were done in response to the representative and [Mr B] suggesting that the delegate’s finding that he had spent a total of [a fewer number of] days in that ten year period, was incorrect. After the hearing, and as discussed in the hearing as the calculations were done under pressure of time, I recalculated the days spent in Australia, and sent a copy of the movement records to the review applicant in that review, [Mr B]. I had subsequently found the correct number of days that [Mr B] had spent in Australia from 20 October 2006 to 20 October 2016 was [a larger number of] days. The review applicant in this review, Mr A], and the visa applicant in this review and the review applicant in the other review, [Mr B], were invited to make submissions on the correct number of days he had been in Australia in that ten year period, which was fair, as the question put to him in the hearing had not used the correct number of days. The review applicants both had the opportunity to respond after the hearing to the correct information.
After the hearing, the representative requested an extension of seven days in which to provide the responses. This request for extension was granted. The representative provided a response, but did not refer to the number of days as calculated from the movement records that the visa applicant had spent in Australia.
I consider the evidence from the review applicant and the visa applicant about the reasons why the visa applicant did not spend many days in Australia, are still relevant to the review, whether they were of the understanding that he had spent 11 days or 14 days, in the ten year period immediately before the dependent child visa was lodged. I accept their evidence in relation to the fact they worked hard, communicated satisfactorily through telephone apps, and travelled overseas to see family members without the visa applicant coming to Australia for many days.
However, I find the relevant point is that the visa applicant was lawfully present in Australia for [a number of] days over a ten year period ending on 20 October 2016, which is less than [a smaller number of] days per year. I am not satisfied that spending [named number of] days in Australia over that ten year period indicates that the two brothers have a close personal relationship dependent upon proximity. It does not indicate that the review applicant’s emotional or psychological health is dependent upon his brother’s presence in Australia.
If I consider the time of application for this visa as the point in time to calculate the total time the visa applicant has spent in Australia, I make the following findings based on the movement records of [Mr B]. The movement records were discussed in the hearing, the representative stated she had not obtained a copy, and the tribunal provided her with a copy after the hearing. In the review applicant’s response and the representative’s submission there was no submission or statement that the movement records could not be relied upon as information of the period of time the visa applicant had spent in Australia.
I make the following findings. The visa applicant has spent [a certain number of] days in Australia in the five years immediately prior to time of application, being May 2013 to May 2018 ([May] 2017 to [later in] May 2017 – [specified] days, and [August] 2016 to [later in] August 2016 – [specified] days), and over the ten years immediately prior to time of application, from May 2008 to May 2018, the applicant has spent [specified] days in Australia ([April [2011] to [later in] April 2011 – [specified]days, and [April] 2009 to [later in] April 2009 – [specified] days, which is an additional [specified] days).

I accept that the review applicant has some health issues, but I also note he is in full time employment, and has been in the same employment as he said for “eight or nine years” which suggests he is managing his health issues. I accept the review applicant is currently accessing treatment for an illness which is particularly [Medical Condition 1] related and complicated by an [different] problem. I accept the review applicant felt everything is happening at once, which included his brother’s application for the visa being refused, and therefore his brother’s visa status has some relevance to his health situation.
I accept the visa applicant has applied for visas to enable him to return to Australia in the last two years, including the visa application which is the subject of this review. However, it is relevant to my assessment of the claimed personal ties with Australia which are of benefit to Australia, that the visa applicant has spent so little time in Australia when he was able to do so. In the ten years immediately prior to the time of application the visa applicant has spent [a number of] days in Australia in total. If I assess the ten year period from when the visa applicant lodged the dependent child visa on 20 October 2016, which is when the visa applicant stated he intended to move to Australia, the visa applicant had spent a total of [specified] days in Australia in the ten years immediately before making that application. I give the fact that the visa applicant spent so little time in Australia in the five and ten year periods immediately before the time of application weight in assessing his personal ties to Australia which are of benefit to Australia.
There is no evidence of long term residence in Australia by the visa applicant; there is evidence of the visa applicant’s absence from Australia excluding the days as set out above. There is no evidence that the visa applicant resides overseas with an Australian citizen partner or child. There is no evidence of an Australian citizen child living in Australia. There is no evidence that the visa applicant owns any Australian real estate or other property or investments. There is no evidence that indicates the visa applicant regards Australia as home.
I accept the visa applicant’s brother resides in Australia, but I also accept that [Mr B] and [Mr A] have resided in separate countries for 19 years. I accept that the brothers communicate regularly, and as [Mr A] stated they did not need to see each other face to face. I have considered that the review applicant would like his brother to live in the same country, and has been affected by the refusal of his brother’s application for the visa. I have considered the considerations of [Mr A]’s current health, and that he has no other relatives that live in Australia. I have also considered the evidence that the review applicant travels regularly to visit his siblings overseas, and his health is such that he remains in full time employment. I give weight to the relatively small number of days the visa applicant has spent in Australia in the last ten years, and with his brother. I accept that [Mr A] would prefer for his brother to live in Australia, or be able to visit Australia, but the evidence before me is that the brothers have a healthy and supportive relationship based on little time spent in the same country and ongoing communication through technological means. Further, I am satisfied that [Mr B]’s visa status is a minor factor in relationship to [Mr A]’s current health issues. The evidence does not suggest that the ties between the review applicant and the visa applicant amounts to evidence that the presence of the visa applicant in Australia would be of benefit to the review applicant or to Australia. I am not satisfied that the sibling relationship between [Mr A] and [Mr B] is evidence of personal ties which are of benefit to Australia.
I have carefully considered all the evidence before me. I am not satisfied that the visa applicant has personal ties with Australia which are of benefit to Australia. I therefore I find the visa applicant does not meet cl.155.212(3).
For the above reasons, the Tribunal is not satisfied that at the time of application the applicant had substantial business, cultural, employment or personal ties with Australia that are of benefit to Australia.
After making this finding the tribunal is not required to consider the remaining criteria for cl.155.212(3).
The tribunal is not satisfied the visa applicant meets the requirements for cl.155.212.
For the reasons above, the Tribunal finds the visa applicant does not meet the criteria for the grant of a Subclass 155 visa.
I have considered whether the visa applicant meets the alternative requirements of a subclass 157 visa.
To meet the requirements of cl.157.212, subclause (1) requires the visa applicant to meet either subclause (2) or (3). I am satisfied the visa applicant does not meet (3) as there is no evidence the visa applicant is the member of a family unit of a person who has been granted a subclass 157 visa, or who meets the requirements of subclause (2) and has lodged a separate application for the 157 visa.
To meet the requirements of cl.157.212(2) the visa applicant must satisfy (b) (i) compelling and compassionate reasons for departing Australia or (ii) if outside Australia, had compelling or compassionate reasons for his or her last departure from Australia. As the visa applicant is outside Australia, the visa applicant has to meet the requirements of subclause (ii), that is, whether there are compelling or compassionate reasons for his or her last departure from Australia.
The visa applicant’s representative submitted that the Department never asked them to provide information about this criterion. I find it is the applicant’s responsibility to provide the information in support of the application for the visa, including in relation to criterion in the same family of visa subclasses.
The representative submitted that the reason for the visa applicant’s last departure from Australia when he returned to [Country 1] [in] May 2017 was for compassionate and compelling circumstances because his child was sick. The representative referred me to a medical certificate provided to the Department. This medical certificate is dated [in] May 2017 and states the child [Master C] is sick suffering from flu and requires rest for one day. The movement records record that the visa applicant arrived in Australia on [in] May 2017. He did not depart until [later in] May 2017. I discussed in the hearing that I am not inclined to find there are compelling and compassionate circumstances because the visa applicant’s child was sick for one day [in] May 2017, and he flew back to [Country 1] [a number of] days later.
In the decision record, the delegate refers to a submission from the visa applicant that he returned to be with his family because the Department notified him of the refusal of the application for the dependent child visa on 5 May 2017. As noted in the Department decision record, the email notification was sent nine days prior to the visa applicant arriving in Australia, and 26 days before he departed. I do not accept there are compelling and compassionate circumstances in this claim where the notification has been given before the visa applicant leaves his family, and where he remains in Australia for 18 days before returning. There is no evidence before me of any stress experienced by the [child], or the visa applicant’s spouse. I accept the child was sick on one day[in] May 2017, and went to the doctor.
After the hearing the visa applicant provided a response through his representative stating that he had to leave Australia urgently because his son was ill. The representative submitted that the child was very ill with an [infection] which he could not ignore and this was his reason for returning to [Country 1]. The representative provided a letter from the visa applicant stating that the child was very sick in September 2016, while he was in Australia. The letter states that the child’s condition was very serious he was crying and asking for the visa applicant and this was the true reason that he returned to [Country 1] from [City 1]. The representative provided a letter from the child’s doctor dated 12 September 2019. The letter confirms that the child was seen [n] September 2016, diagnosed with an [infection] and prescribed medications. The month of September is recorded by the numeral ‘9’ in the doctor’s letter in both the date of the letter and the date of the child’s illness. In the date of the letter the numeral ‘9’ is recorded in both the month and the year. I am satisfied that the numeral ‘9’ represents September, when referring to the date the child was seen by the doctor. This is relevant because according to the movement records, which had been provided to the visa applicant by the tribunal, he was not in Australia in September 2016. In the year 2016, according to the movement records, [Mr B] was in Australia from [August] 2016 to [later in] August 2016. The fact that his son was ill with a [infection] [in] September 2016 is irrelevant to my considerations.
The representative submits that the tribunal should schedule a further hearing to discuss the child’s illness to enable the visa applicant to provide additional information from the doctor. The tribunal has considered the information from the doctor. I accept the child was ill [in] September 2016, however as [Mr B] was not in Australia at that time, and his last departure from Australia occurred the following May, this information is not relevant to whether the visa applicant meets the criteria of cl.157.212(2)(b)(ii). The relevant information in relation to consideration of this aspect of the criteria for the subclass 157 visa, is whether there are compelling or compassionate reasons for the visa applicant’s last departure from Australia. The visa applicant’s last departure from Australia was [in] May 2017. I discussed this issue with the visa applicant and review applicant in the hearing. I have considered the matters that were put forward by the visa applicant to the Department, and in written submissions and orally at the hearing. I am satisfied that all procedural fairness has been offered to the visa applicant in this regard. I do not intend to schedule a further hearing to enable the applicant to give additional information as requested by the representative, including information from the doctor about the child’s illness in September 2016, or to consider the grant of a subclass 157 visa for the applicant. I am satisfied that the review applicant has had every opportunity to provide information both prior to and during the hearing and after the hearing in relation to the criteria for the relevant visa subclasses.
I have considered the representative’s submissions, both written and oral. I have considered the visa applicant’s evidence and the evidence of all the witnesses in the combined hearing. I am not satisfied that considered individually or collectively, there are compelling and compassionate reasons for the visa applicant’s last departure from Australia.
I have considered the claims of compelling and compassionate reasons for the visa applicant’s last departure from Australia on 31 May 2017. I am not satisfied there are compelling and compassionate reasons for the visa applicant’s last departure from Australia.
I therefore find the visa applicant does not meet the requirements of cl.157.212(2)(b). The visa applicant does therefore not satisfy cl.157.212.
DECISION
The Tribunal affirms the decision not to grant the visa applicant a Return (Residence) (Class BB) visa.
Margie Bourke
Member

ATTACHMENT – RELEVANT LAW
Migration Regulations 1994
Schedule 2, Part 155
…
155.212(1) The applicant meets the requirements of subclause (2), (3), (3A) or (4).
…
(3)The applicant meets the requirements of this subclause if the applicant is outside Australia, and the Minister is satisfied that the applicant has substantial business, cultural, employment or personal ties
with Australia which are of benefit to Australia, and the applicant:
(a)has not been absent from Australia for a continuous period of 5 years or more immediately before the application for the visa, unless there are compelling reasons for the absence, and the applicant:
(i)holds a permanent visa; or
(ii)last departed Australia as an Australian permanent resident; or
(iii)last departed Australia as an Australian citizen, but has subsequently lost or renounced Australian citizenship; or
(b)was an Australian citizen, or an Australian permanent resident, less than 10 years before the application, and has not been absent from Australia for a period of, or periods that total, more than 5 years in the period from the date that the applicant last departed Australia as an Australian citizen or Australian permanent resident to the date of the application, unless there are compelling reasons for the absence.

[2019] AATA 6589

23 September 2019

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Jurisdiction

Statutory Construction

Procedural Fairness