1935068 (Refugee)
[2022] AATA 2451
•28 May 2022
1935068 (Refugee) [2022] AATA 2451 (28 May 2022)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER: 1935068
COUNTRY OF REFERENCE: Afghanistan
MEMBER:Sean Baker
DATE:28 May 2022
PLACE OF DECISION: Melbourne
DECISION:The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(a) of the Migration Act.
Statement made on 28 May 2022 at 10:35pm
CATCHWORDS
REFUGEE – protection visa – Afghanistan – imputed political opinion – anti-Taliban – race – mixed Hazara/Qizibash ethnicity – religion – Shia – particular social group – people who worked for and are associated with Western NGOs/Western governments – human rights violations by Taliban – risk of mass casualty attacks – Islamic State in Khorasan Province (ISKP) – evidence of ethnic cleansing – decision under review remittedLEGISLATION
Migration Act 1958 (Cth), ss 5H, 5J, 5K, 5L, 5LA, 36, 65, 499
Migration Regulations 1994 (Cth), Schedule 2Any 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 4 December 2019 to refuse to grant the applicant a protection visa under s 65 of the Migration Act 1958 (Cth) (the Act).
The applicant who claims to be a citizen of Afghanistan, applied for the visa on 27 May 2016. The delegate refused to grant the visa on the basis that the delegate did not accept the applicant’s claims he would be harmed for his imputed political opinion, nor that he was Hazara as claimed.
The applicant was represented in relation to the review.
CRITERIA FOR A PROTECTION VISA
The criteria for a protection visa are set out in s 36 of the Act and Schedule 2 to the Migration Regulations 1994 (Cth) (the Regulations). An applicant for the visa must meet one of the alternative criteria in s 36(2)(a), (aa), (b), or (c). That is, he or she is either a person in respect of whom Australia has protection obligations under the ‘refugee’ criterion, or on other ‘complementary protection’ grounds, or is a member of the same family unit as such a person and that person holds a protection visa of the same class.
Section 36(2)(a) provides that a criterion for a protection visa is that the applicant for the visa is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee.
A person is a refugee if, in the case of a person who has a nationality, they are outside the country of their nationality and, owing to a well-founded fear of persecution, are unable or unwilling to avail themselves of the protection of that country: s 5H(1)(a). In the case of a person without a nationality, they are a refugee if they are outside the country of their former habitual residence and, owing to a well-founded fear of persecution, are unable or unwilling to return to that country: s 5H(1)(b).
Under s 5J(1), a person has a well-founded fear of persecution if they fear being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, there is a real chance they would be persecuted for one or more of those reasons, and the real chance of persecution relates to all areas of the relevant country. Additional requirements relating to a ‘well-founded fear of persecution’ and circumstances in which a person will be taken not to have such a fear are set out in ss 5J(2)-(6) and ss 5K-LA, which are extracted in the attachment to this decision.
If a person is found not to meet the refugee criterion in s 36(2)(a), he or she may nevertheless meet the criteria for the grant of the visa if he or she is a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of being removed from Australia to a receiving country, there is a real risk that he or she will suffer significant harm: s 36(2)(aa) (‘the complementary protection criterion’). The meaning of significant harm, and the circumstances in which a person will be taken not to face a real risk of significant harm, are set out in ss 36(2A) and (2B), which are extracted in the attachment to this decision.
Mandatory considerations
In accordance with Ministerial Direction No.84, made under s 499 of the Act, the Tribunal has taken account of the ‘Refugee Law Guidelines’ and ‘Complementary Protection Guidelines’ prepared by the Department of Home Affairs, and country information assessments prepared by the Department of Foreign Affairs and Trade expressly for protection status determination purposes, to the extent that they are relevant to the decision under consideration.
CONSIDERATION OF CLAIMS AND EVIDENCE
The issue in this case is whether the applicant has a well-founded fear of persecution for one of the enumerated reasons on return to Afghanistan or, if not, whether there is a real risk he will suffer significant harm on return to Afghanistan. For the following reasons, the Tribunal has concluded that the matter should be remitted for reconsideration.
Claims and evidence
On the Department file are:
· •the applicant’s two most recent Afghan passports
· A copy of his Taskera
· His Australian marriage certificate.
As did the delegate, I accept this information is genuine and I accept that the applicant is a national of Afghanistan.
The applicant claims that he will be harmed as a person of mixed Hazara/Qizibash ethnicity and Shia religion.
He claims that in 2006 he worked at a Western [business], including serving alcohol.
He worked for a number of other companies which were Western NGOs or associated with Western forces.
The applicant provided letters evidencing his work for the following employers:
· [Employer 1] letter, undated (copy)
· [Employer 1] letter, 2013-05-12(copy)
· [Employer 1], vaccination certificate(copy)
· [Employer 1], blood group certificate (original)
· Group photograph(copy)
· [Employer 1] magazine cover (copy)
· [Employer 2] letter,30 July 2013(copy)
· [Employer 3], salary receipts July 2014, August 2014, September 2014 (copy)
· [Employer 3], certificate of service, 27 May 2014(copy)
· [Employer 3], certificate of employment, 25 October 2014(copy)
· [Employer 3], staff ID card, expiry 31 December 2014
· Letter [Employer 3], 23 May 2016 (copy)
· Letter [Employer 3], 23 May 2016(copy)
· [Employer 4], ID card, expiry 31 December 2017
The delegate rejected these documents as establishing that the applicant had worked for a range of Western NGOs and businesses affiliated with Western agencies and businesses. The delegate’s reasoning does not support the conclusions they have drawn, the minor and in many cases irrelevant concerns they have with aspects of the document do not support making the significant finding that the documents are non-genuine.
The delegate has also taken account of irrelevant considerations, including the conduct of the applicant in Australia towards his ex-wife and her family. I agree that this conduct is of concern, but it has not been explained nor can I determine how it is relevant to the applicant’s claims to fear harm on return to Afghanistan.
Having considered the evidence provided by the applicant, the concerns of the delegate, and the information provided to me by the applicant rebutting the concerns of the delegate and the attached documents, I find that the applicant’s explanations are entirely convincing.
I accept that the applicant worked for a range of companies associated with the West.
Country information
Following 20 years of insurgency, the Taliban took control of Kabul and almost all of the rest of Afghanistan on 15 August 2021 and declared an Islamic Emirate of Afghanistan. International forces departed and aid money directly to the previous Afghan government stopped, and many of the assets of the previous Afghan government were frozen overseas.
The economy is in crisis and close to or in collapse and food shortages have been widely reported. Much of the population suffers acute food insecurity[1] The Taliban set up an ‘interim government’ in September and October 2021, with the announcement of some 88 appointments across 30 ministries. The occupants of these positions are mostly Pashtun and chiefly long-serving Taliban commanders with little relevant government experience. There are no women among them and few representatives of ethnic minorities.[2]
[1] UN High Commissioner for Refugees (UNHCR), UNHCR Guidance Note on the International Protection Needs of People Fleeing Afghanistan, February 2022, available at: DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
Despite statements to the contrary from Taliban leaders including Sirajuddin Haqqani, leader of the HQN and deputy leader of the Taliban, there have been waves of killings of journalists, human rights activists, judicial workers, doctors and clerics.[3] Whilst the takeover by the Taliban means there has been a reduction in mass casualty attacks perpetrated by the Taliban, Islamic State in Khorasan Province (ISKP) has perpetrated mass casualty attacks since August 2021. While indiscriminate attacks by the Taliban and elements associated with it have reduced, there are concerns about ongoing targeted violence and serious human rights violations by the Taliban and its affiliates.[4] The relative peace may be further frayed if the economic situation worsens or the unstable network of alliances of groups pledged to the Taliban becomes unstable.
[3] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
[4] UN High Commissioner for Refugees (UNHCR), UNHCR Guidance Note on the International Protection Needs of People Fleeing Afghanistan, February 2022, available at: >
UNHCR and others have highlighted the widespread human rights violations in Afghanistan, giving rise to an increase in the need for international protection for people fleeing Afghanistan, including, inter alia, women and girls as well as ethnic and religious minorities.[5]
[5] UN High Commissioner for Refugees (UNHCR), UNHCR Guidance Note on the International Protection Needs of People Fleeing Afghanistan, February 2022, available at: >
The overwhelming majority of Afghan Shi’a are Hazara, although a small number of Hazara are Sunni. There are also some Shi’a from other ethnic groups, including some Pashtun, Tajiks and Turkic peoples. The Taliban, ISKP, Al-Qa’ida and most other terrorist/insurgent forces in Afghanistan are Sunni. While Sunni and Shi’a Muslims have lived side-by-side for much of Afghanistan’s history, religious hardliners such as the Taliban typically do not consider Shi’a to be true Muslims. [6]
[6] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
ISKP attacks since August 2021 have targeted Shia mosques. The Taliban, since taking control of the country, have summarily executed Hazaras who were former members of the security forces and hundreds of Hazara families have been forcibly evicted from their homes in central Afghanistan.[7] Whilst the Taliban claim the evictions are due to property disputes, some NGOs consider this ethnic cleansing.[8] It is worth noting that the Taliban target the Hazara ethnicity because of their Shia faith.
[7] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
[8] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
DFAT assesses that Shi’a face a high risk of being targeted by ISKP and other militant groups on the basis of their religious affiliation when assembling in large and identifiable groups, such as during demonstrations or when attending mosques during major religious festivals. This risk increases for those living in Shi’a majority or ethnic Hazara neighbourhoods in major cities such as Kabul and Herat.[9]
[9] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
Little information can be located on the Qizibash/Qizilbash. The information that can be found indicates that they are Shia, are Dari speakers, usually live in urban areas, historically the Qizilibash had a prominent role in the bureaucracy, have held important administrative and professionals positions, engage in trade, and are amongst the more literate groups in Afghan society, there were periods in the past when they claimed to be Tajiks (who are generally Sunni), and that estimates of their numbers vary from 50,000 to 200,000 and even higher.[10]
[10] Library of Congress (U.S.)/Peter R. Blood (ed.) (2001): Afghanistan: A Country Study. Washington: GPO for the Library of Congress, (Naval Post Graduate School (United States),Program for Culture and Conflict Studies, Kabul Provincial Overview, March 2017, GlobalSecurity, Afghanistan - Other Groups, 21 August 2012, Shah Mahmoud Hanifi, American Historical Association: Religious Freedom in Islamic History, Roundtable ‘Making Space for Shi'ism in Afghanistan's Public Sphere and State Structure’ 1 July 2015, ‘Qizilbash people of Afghanistan’, South Turkistan Word Press (Afghanistan), 9 October 2009,
Prior to August 2021, as an insurgency, the Taliban targeted Afghans working for, supporting or associated with the then Afghan government and international agencies. Such people were subject to intimidation, threats, abduction, and targeted killings.[11] Despite a claimed amnesty for such people form the Taliban, there have been credible reports of assassinations and other harm visited on members of the former security forces, the arbitrary detention of civilians who worked for previous administrations and their family members and the killing of former Afghan interpreters and other locally-engaged personnel who assisted US or other allied forces.[12] Such reports led DFAT to assess that former security forces, as well as former government officials who were openly critical of the Taliban or harmful to Taliban interests (such as judges or police responsible for imprisoning Taliban soldiers) are also at moderate to high risk of unwanted attention, detention, harassment and violence, while ordinary and/or technical government officials were assessed to be at low risk of adverse Taliban attention.[13] However, this later assessment appears in doubt given investigations and credible reports of widespread, ubiquitous killings and disappearances of former government officials of all levels.[14]
[11] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
[12] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
[13] DFAT Thematic Report Afghanistan - Political and Security Developments August 2021 to January 2022 (14 January 2022).
[14] New York Times, ‘The Taliban Promised Them Amnesty. Then They Executed Them.’ NY Times, 12 April 2022, Opinion | The Taliban Promised Them Amnesty. Then They Executed Them. - The New York Times (nytimes.com); EUAA, Country Guidance: Afghanistan Common analysis and guidance note, April 2022, Country Guidance Afghanistan (europa.eu)
Consideration
As above, I accept that the applicant worked for a range of companies associated with the West.
Having regard to his evidence and his claims of his family and growing up, as well as his work and educational profile, I accept that the applicant, as he claims, is of mixed Hazara and Qizilbash ethnicity. Given his ethnicity and the country information above, I accept that the applicant is a Shia Muslim.
The Taliban, having seized control of the country, have access to all the records of the previous government. I find that if the applicant returns, there is a real chance he will come to the attention of the Taliban because of his past work history, and would be imputed with an anti-Taliban opinion because of it. I find that there is a real chance the applicant could be detained, beaten or otherwise seriously harmed by the Taliban for these reasons. There is a real chance his religion / ethnicity would lead to him being targeted by the Taliban and also by the ISKP for serious harm including attacks, detention or other serious harm.
Having regard to the information before me and the claims of the applicant, which I have accepted above, I find that the applicant faces a real chance of serious harm if he returns to Afghanistan from the Taliban who have taken over the country. Such harm would be for reasons of his religion as a Shia Muslim, his ethnicity as a Hazara/Qizilbash and his membership of a particular social group of those who have worked for and are associated with Western NGOs/Western governments. These reasons would be the essential and significant reasons for the harm from the Taliban administration or the ISKP. The harm would constitute serious harm including his arrest, detention, assault and possible death. In particular the confluence of his religion/ethnicity with his past work for Western NGOs would place him at very high risk of more extreme forms of serious harm. Such harm would constitute systematic and discriminatory conduct because it would be non-random and targeted at the applicant for one or more of these reasons.
The applicant cannot alter his behaviour to obscure these characteristics, they are either innate or immutable including his race, and his past work history, or fundamental to his identity and conscience, being his faith.
Effective state protection cannot be accessed by the applicant, he fears harm from the Taliban who control effectively all of Afghanistan, or form the ISKP who are unchecked in their ability to strike at Shia targets. Nor can he relocate within Afghanistan for the same reason.
Having regard to all of the information before me, I find that the applicant has a well-founded fear of persecution by the Taliban and ISKP for reasons of his religion, ethnicity and membership of the above particular social groups if he returns to Afghanistan now or in the reasonably foreseeable future.
Conclusion
For the reasons given above, the Tribunal is satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(a).
DECISION
The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(a) of the Migration Act.
Sean Baker
MemberATTACHMENT - 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.
…
Key Legal Topics
Areas of Law
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Immigration
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Administrative Law
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Statutory Interpretation
Legal Concepts
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Judicial Review
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Procedural Fairness
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Statutory Construction
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Remedies
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Natural Justice
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