2002195 (Migration)

2002195 (Migration) [2021] AATA 3573 (20 August 2021)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER: 2002195
MEMBER:David McCulloch
DATE:20 August 2021
PLACE OF DECISION: Sydney
DECISION:The Tribunal affirms the decision to cancel the applicant’s Subclass 500 (Student) visa.

Statement made on 20 August 2021 at 8:56am
CATCHWORDS
MIGRATION – cancellation –Student (Temporary) (Class TU) visa – Subclass 500 visa – applicant provided incorrect answers – applicant failed to disclose criminal charges – applicant did not study for a lengthy period of 18 months – charge against him was withdrawn and dismissed – decision under review affirmed
LEGISLATION
Migration Act 1958, ss 101, 107, 109
Migration Regulations 1994 (Cth) r 2.41
CASES
MIAC v Khadgi (2010) 190 FCR 248

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 dated 31 January 2020 to cancel the applicant’s Subclass 500 (Student) visa under s.109(1) of the Migration Act 1958 (the Act).
The visa that was cancelled was granted on 24 September 2019 for a stay period until 20 March 2022.
The delegate cancelled the visa on the basis that the applicant had provided incorrect answers in a visa application, breaching s.101(b) of the Act and, in the circumstances, the visa ought to be cancelled. The issue in the present case is whether that ground for cancellation is made out, and if so, whether the visa should be cancelled.
The applicant appeared before the Tribunal on 11 August 2021 at 9.30am to give evidence and present arguments.
The Tribunal exercised its discretion to hold the hearing by video using Microsoft Teams. The hearing was held during the COVID-19 pandemic. The Tribunal determined it was reasonable to hold a hearing in this manner, having regard to the nature of this matter and the individual circumstances of the applicant. The Tribunal also had regard to the Tribunal’s objective of providing a mechanism of review that is fair, just, economical and quick, and the delay to the matter if the hearing was not to be conducted remotely. The Tribunal is satisfied that the applicant was given a fair opportunity to give evidence and present arguments.
The applicant was represented in relation to review by his registered migration agent, who attended the hearing.
For the following reasons, the Tribunal has concluded that the decision to cancel the applicant’s visa should be affirmed.
CONSIDERATION OF CLAIMS AND EVIDENCE
Section 109(1) of the Act allows the Minister to cancel a visa if the visa holder has failed to comply with ss.101, 102, 103, 104, 105 or 107(2) of the Act. Broadly speaking, these sections require non-citizens to provide correct information in their visa applications and passenger cards, not to provide bogus documents and to notify the Department of any incorrect information of which they become aware and of any relevant changes in circumstances.
The exercise of the cancellation power under s.109 of the Act is conditional on the Minister issuing a valid notice to the visa holder under s.107 of the Act, providing particulars of the alleged non-compliance. Where a notice is issued that does not comply with the requirements in s.107, the power to cancel the visa does not arise. Extracts of the Act relevant to this case are attached to this decision.
In the present matter, the Tribunal is satisfied that the delegate had reached the necessary state of mind to engage s.107 and that the notice issued under s.107 complied with the statutory requirements.
Was there non-compliance as described in the s.107 notice?
The issue before the Tribunal is whether there was non-compliance in the way described in the s.107 notice, being the manner particularised in the notice, and if so, whether the visa should be cancelled. The non-compliance identified and particularised in the s.107 notice was non-compliance with s.101(b). The s.107 notice advised relevantly as follows:
Evidence of non-compliance
On [date] December 2018 [name deleted] (the visa holder) arrived in Australia holding a Student (subclass 500) visa with an expiry date of 26 August 2019.
On 23 August 2019 the visa holder lodged an application for a further Student visa using the online lodgement facility. In the online application form the visa holder provided the following answers and information (in italics):
Primary Applicant Passport details
Family name:    [deleted]
Given names:    [deleted]
Sex:     MALE
Date of birth:     [deleted]
Passport number:        [deleted]
Country of passport: PERU
Character declarations (page 13)
If the applicant answers ‘Yes’ to any of the character declarations they must give all relevant details. For combined applications, state which applicant the declaration applies to.
If the matter relates to a criminal conviction, provide:
•         the date and nature of the offence
•         full details of the sentence
•         dates of any period of imprisonment or other detention
Has any applicant ever been charged with any offence that is currently awaiting legal action?
NO
Declarations Warning:
Giving false or misleading information is a serious offence. The applicants declare that they:
Have read and understood the information provided to them in this application
YES
Have provided complete and correct information in every detail on this form, and on any attachments to it.
YES
Understand that if documents are found to be fraudulent or information to be incorrect after the grant of a visa, the visa may subsequently be cancelled.
YES
Based on the above answers and information and having satisfied the relevant criteria, the visa holder was granted his Student (subclass 500) visa on 24 September 2019.
On 5 December 2019 the department received information that on [date] July 2019 the visa holder was charged by New South Wales (NSW) Police with the following offence:
-         Affray
On [date] July 2019 it was alleged the visa holder used unlawful violence towards the victim by conduct such that a person of reasonable firmness if present at the scene would have feared for their safety.
His next court appearance is scheduled for [April] 2020 at [a] Local Court.
Based on the above information it appears the visa holder provided an incorrect answer in his application for Student (subclass 500) visa as follows:
On page 13 of the online application form for Student visa, the visa holder answered ‘NO’ to the question ‘Has any applicant ever been charged with any offence that is currently awaiting legal action?’ I consider this answer to be incorrect because prior to lodging his visa application on 23 August 2019 the visa holder was charged with Affray by NSW Police on [date] July 2019, a matter that is currently awaiting legal action.
By not disclosing that he had a criminal charge in the state of New South Wales, it appears the visa holder failed to comply with section 101(b) of the Migration Act 1958. As such his Student (subclass 500) visa is under consideration for cancellation under section 109 of the Migration Act 1958.
In the submission on the applicant’s behalf to the Department, in response to the s.107 notice, it was accepted that the applicant had provided incorrect information. It was claimed that this was inadvertent.
Claims of the statement being inadvertent are considered in matters pertaining as to whether the visa should be cancelled.
In the hearing the applicant agreed again that the information was incorrect in terms of the answer ‘no’ as to whether there were criminal charges laid against the applicant.
For these reasons, the Tribunal finds that there was non-compliance with s.101(b) by the applicant in the way described in the s.107 notice.
Should the visa be cancelled?
As the Tribunal has decided that there was non-compliance in the way described in the notice given to the applicant under s.107 of the Act, it is necessary to consider whether the visa should be cancelled pursuant to s.109(1). Cancellation in this context is discretionary, as there are no mandatory cancellation circumstances prescribed under s.109(2).
In exercising this power, the Tribunal must consider the applicant’s response (if any) to the s.107 notice about the non-compliance, and have regard to any prescribed circumstances: s.109(1)(b) and (c). The prescribed circumstances are set out in r.2.41 of the Migration Regulations 1994. Briefly, they are:
·     the correct information
·     the content of the genuine document (if any)
·     whether the decision to grant a visa or immigration clear the visa holder was based, wholly or partly, on incorrect information or a bogus document
·     the circumstances in which the non-compliance occurred
·     the present circumstances of the visa holder
·     the subsequent behaviour of the visa holder concerning his or her obligations under Subdivision C of Division 3 of Part 2 of the Act
·     any other instances of non-compliance by the visa holder known to the Minister
·     the time that has elapsed since the non-compliance
·     any breaches of the law since the non-compliance and the seriousness of those breaches
·     any contribution made by the holder to the community.
While these factors must be considered, they do not represent an exhaustive statement of the circumstances that might properly be considered to be relevant in any given case: MIAC v Khadgi (2010) 190 FCR 248. The Tribunal may also have regard to lawful government policy. The relevant policy is set out in the Department’s Procedural Advice Manual (PAM3) ‘General visa cancellation powers’, which refers to matters such as the consequences of cancelling the visa, international obligations and any other relevant matters.
The correct information would have been for the applicant to have answered ‘yes’ to the question, ‘[h]as any applicant been charged with any offence that is currently awaiting legal action?’.
Relevant details are that at the time the applicant submitted his application for the student visa he had been charged with ‘affray’ by New South Wales Police on [date] July 2019, and that the matter was awaiting legal action.
The content of the genuine document is not a relevant factor in this matter.
Character assessments would have been relevant in the determination of the application for the student visa in question. The existence of criminal charges against the applicant would have been matters adverse to the applicant that would have been considered in the ultimate decision as to whether the visa ought to have been granted. Whilst criminal charges would not necessarily have been determinative factors towards an adverse decision, they would certainly have been taken partially into account.
Therefore, given that the decision to grant the visa was made at least partially based on incorrect information, this is a discretionary factor adverse to the applicant.
The Tribunal considers the circumstances in which the non-compliance occurred. The submission on behalf of the applicant to the Department indicated that the inclusion of the incorrect information was inadvertent. It is claimed that the applicant thought the question related to a matter that had been ‘resolved’ or finalised. As the matter was in the process of reaching a verdict, the applicant thought that the answer should be ‘no’.
This and other submissions are made in an additional statement to the Tribunal as follows:
·I was born on [date] and I am currently [age] years old.
·I understand that even though my student application was completed by my student agent, I am legally responsible for the answers.
·I truly and sincerely say that I have never intended to mislead the Department of Home Affairs when I answered "No" to the question as to whether I had been charged with an offence. The reason I answered the question the way I did was because I did not fully understand the word "charged". I am not trying to excuse my conduct but it is an explanation to my error. I thought that word "charged" is when the court finds you guilty for a criminal act or go to jail.
·From this experience I have learned that if I do not understand a question in the future, I will seek help to avoid making any mistakes. I truly say that if I am given another chance, I will never make such a mistake.
·In court I pleaded not guilty to "affray" because I was not guilty. My lawyer that represented me in court told me that the police had taken the case out of court and the court dismissed the affray matter.
·I have no criminal record. My intention is to continue studying in Australia and keep learning in this country
·I know that with whole situation I have let me parents down whom are supporting me financially here in Australia. With this situation I have let many people down.
·I respectfully ask the tribunal for another chance to allow me keep my student visa
In the hearing, the applicant confirmed that he answered ‘no’ to the question of criminal charges inadvertently without a deliberate intention to deceive.
The Tribunal discussed with the applicant in the hearing the following to counter his claims that he answered the question inadvertently in misunderstanding its meaning.
The Tribunal put to the applicant that it would consider that he would have been acutely conscious in answering character questions that the existence of criminal charges against him could or would be relevant factors. This would, in the Tribunal’s view, result in a person in the applicant’s position very carefully considering and checking questions relating to character and the existence of criminal charges, including to have checked with others if unclear as to the wording and the meaning of the questions asked.
The Tribunal also noted that the previous information in the character declaration section of the application had referred to convictions, which leads to questions as to whether the applicant would have been confused that the subsequent question referring to charges actually was referring to convictions.
The Tribunal notes that the applicant answered ‘yes’ to the question in the application as to whether he had read and understood the information provided to him in the application.
The applicant also noted that the applicant had a migration agent who would have been available to answer queries if there was uncertainty as to the meaning of the question about charges.
Further, at the time of the application the applicant had been studying English in Australia for more than eight months. The Tribunal noted that the applicant had provided a two and a half page written statement to the Department in support of his student application which is declared to have been true and correct and written in the applicant’s own words. The Tribunal noted that this statement is well-written. The fact of the applicant providing this well expressed submission in his own words is not consistent with claims that the applicant, through comprehension difficulties with English, would have been confused as to the meaning of the question in the application form which he has stated to have incorrectly answered inadvertently.
All these questions were variously put, some repeatedly, to the applicant during the course of the hearing. Often, instead of answering the particular concern put, the applicant simply repeated that the answer to the question was inadvertent because of not understanding the meaning of the word ‘charges’ and thinking that this meant a conviction. The applicant indicated that there was not an intention to deliberately deceive.
The applicant further indicated that he was only [age] years old, did not know about procedures and it was his first time in terms of having to deal with something like this. He indicated that he had not been studying English in Australia for that long and key words in the application were complex.
The applicant’s migration agent provided oral submissions on these issues at the end of the hearing. The agent submitted that the applicant acknowledges his mistake as [age]-year-old, but this was not an excuse. It was open to conclude that the applicant should have known the distinction between conviction and charges. It is submitted that the Tribunal needs to consider that the applicant did not mean to mislead.
The Tribunal makes allowances for the age of the applicant and him only having been in Australia learning English for a period of eight months. Nevertheless, in the context of the applicant having the assistance of a migration agent in filling in the application, the charges against him having only been recently laid against him, the Tribunal maintains that the applicant would have or should have been acutely conscious that the criminal charges were very relevant to questions relating to character.
Considering the Tribunal’s concerns put the applicant and the applicant’s responses, the Tribunal considers that the applicant should have been aware of the potential for an obligation to have disclosed the criminal charges against him, meaning that he should have checked very carefully the precise meaning of the questions asked relating to character. The Tribunal considers that there was either actual knowledge or, at least, a wilful disregard as to the questions relating to charges that were being asked of him in terms of his character. As indicated, the Tribunal has credibility concerns that the applicant would have thought that the word ‘charges’ in fact meant a ‘conviction’, given the use of these two separate terms in the application. If the applicant was in doubt as to meaning of terms he should have asked his migration agent.
Given the Tribunal’s assessment in this respect, it does not accept that the response was inadvertent or understandable. The fact that the Tribunal considers that the applicant either deliberately answered the question incorrectly or had a wilful disregard for the question undermines their claim that the response was inadvertent. This is a negative factor for the applicant assessing whether the Tribunal should exercise its discretion to cancel the visa.
Regarding the present circumstances of the visa holder in terms of his study, the applicant in the hearing indicated that his last study was in January 2020. The applicant indicated that previously he had been studying English, but in his time studying (from the beginning of 2019) he had passed no courses. The applicant indicates that he still has several months to go before completing his intermediate English course.
The Tribunal noted to the applicant that there was no condition on his Bridging visa restricting his study and asked why he had not continued his study. In response, the applicant indicated that there were multiple compounding issues that were barriers, including the death of his grandparents in Peru from COVID-19 which greatly upset him. The applicant referred to the fact that his English school closed down. The applicant also referred to difficulties resulting from COVID-19.
The Tribunal asked the applicant what he would do if the visa was reinstated. The applicant indicated that he wants to make a better life for himself in Australia. Both the applicant and the applicant’s migration agent indicated that the applicant now wishes to continue his study, firstly by completing his English course and then undertaking a course in marketing.
After the hearing, a confirmation of enrolment was provided in a Certificate IV in Marketing and Communication commencing on 31 January 2022. The applicant did not provide, as he indicated that he would in the hearing, a confirmation of enrolment in an English course that he said he would need to complete before starting his Certificate IV.
Whilst the Tribunal makes some allowances for personal issues affecting the applicant, including the death of his grandparents, COVID-19 and the applicant’s English school closing down, the Tribunal maintains concerns that the applicant did not study for a lengthy period of 18 months. If the applicant’s English school closed down he should have found another school. Sydney was COVID free for much of 2020. The applicant in the hearing indicated he only has a few months left to complete his intermediate English course as a prerequisite to further study, and the Tribunal entertains concerns that this study was not embarked on from early 2020 until mid-2021.

The lack of study by the applicant over the past 18 months is adverse in terms of discretionary factors. So too is the fact that the applicant has not completed one course in his two and a half years in Australia.
There is no issue adverse to the applicant in terms of his behaviour concerning his obligations under Subdivision C of Division 3 of Part 2 of the Act.
In terms of other instances of non-compliance known, the Tribunal has information from the applicant that the charge against him was withdrawn and dismissed on [date] March 2020. This is relevant, because if the applicant had been convicted of criminal charges that could be a ground on which the visa could be cancelled. A factor in the applicant’s favour is the fact that the applicant has not been convicted of the charges against him and that the allegations have not been proved.
Approximately two years have passed since the non-compliance, which is a period of time in which the applicant has been able to further integrate with the Australian community. The Tribunal does not think this is an overly extensive period of time such as to create significant reintegration issues in having to return to his home country. In any event, the applicant has always been in Australia on a temporary visa with an obligation to return to his home country.
In relation to breaches of the law since non-compliance, the Tribunal notes as indicated above that the charges against the applicant have been withdrawn and dismissed. This is given some weight in the applicant’s favour. There is no evidence of any other breaches.
The applicant in the hearing did not indicate any specific activities which would be relevant to him having made contributions to the Australian community.
The Tribunal considers other discretionary factors, particularly relevant discretionary factors set out in the Department’s PAM3.
The Tribunal considers the hardship to the applicant if the visa remains cancelled. In the hearing he indicated that cancellation will mean he will not be able to make a better life for himself in Australia and continue his studies. The Tribunal accepts there will be some hardship in this respect, although if the applicant was seriously committed to his studies it considers that he would have studied in the last year and a half. The applicant has always been in Australia on a temporary visa, therefore he has an obligation to return to his home country. Nevertheless, the Tribunal accepts some hardship to the applicant in terms of not being able to stay in Australia for as long as he would wish.
There is no evidence that there are other persons whose visas would, or may be, cancelled consequently upon the cancellation of the applicant’s visa.
There is no information to suggest that Australia’s obligations under relevant international agreements would or may be breached as a result of the visa being cancelled.
In the hearing the applicant, in relation to returning to Peru, indicated that he had no fear of serious significant harm in Peru that would make him eligible for a Protection visa. Given that evidence, Australia’s non-refoulment obligations are not a relevant discretionary factor.
In terms of mandatory legal consequences of a cancellation decision, the Tribunal accepts that this would limit the types of other Australian visas that the applicant could apply for and that this is a detriment to the applicant if the visa is cancelled.
If the applicant’s visa is cancelled he could become an unlawful noncitizen with the possibility of being subject to detention. However, the applicant would have continuing eligibility for a Bridging visa to make his status lawful as he makes arrangements to leave the country.
The applicant provided the following to the Tribunal:
·A character reference letter from [Mr A] , dated 2 August 2021, which states that [Mr A] has known the applicant since January 2019 as the applicant’s supervisor and friend. The letter states that the applicant is an ‘incredibly gentle, patient person who has been going through an extremely difficult time’.
·A letter from [a] Student Counsellor at [a named] Agency, undated, which states that the applicant is a ‘good and decent student, and has an excellent behaviour and compromise with his academic life in Australia’.
·The applicant’s Nationally Coordinated Criminal History Check Certificate, dated [August] 2021, which shows that as of 7 July 2021, there was no disclosable court outcome related to the applicant.
Testimonials as to the applicant’s good character and being a good student are discretionary factors considered in the applicant’s favour.
These are the relevant discretionary factors which the Tribunal considers are pertinent in this matter.
The Tribunal weighs competing discretionary factors. Key issues adverse to the applicant are that the Tribunal considers the incorrect answer was provided either deliberately or with wilful disregard to needing, or making appropriate enquiries as to needing, to disclose to the Department the charges that had been laid against him. The disclosure of criminal charges would have been one negative factor that would have been considered by the Department in determining whether to grant him the student visa. Adverse to the applicant is his failure to undertake any study in Australia in the last year and a half. In the applicant’s favour is the fact that the charges against him have been withdrawn and dismissed. The Tribunal accepts some degree of hardship to the applicant if he is not able to continue to make a life for himself in Australia, and is prevented from his more recent commitment to continue his studies. The Tribunal accepts that there are testimonials as to the applicant’s good character.
Balancing discretionary factors, the Tribunal considers that matters adverse to the applicant outweigh issues in his favour. The Tribunal exercises its discretion to cancel the visa.
The Tribunal has decided that there was non-compliance by the applicant in the way described in the notice given under s.107 of the Act. Further, having regard to all the relevant circumstances, as discussed above, the Tribunal concludes that the visa should be cancelled.
DECISION
The Tribunal affirms the decision to cancel the applicant’s Subclass 500 (Student) visa.
David McCulloch
Member

ATTACHMENT – Migration Act 1958 (extracts)
5Interpretation
(1)In this Act, unless the contrary intention appears:
bogus document, in relation to a person, means a document that the Minister reasonably suspects is a document that:
(a)     purports to have been, but was not, issued in respect of the person; or
(b)     is counterfeit or has been altered by a person who does not have authority to do so; or
(c)      was obtained because of a false or misleading statement, whether or not made knowingly.
97Interpretation
In this Subdivision:
application form, in relation to a non‑citizen, means a form on which a non‑citizen applies for a visa, being a form that regulations made for the purposes of section 46 allow to be used for making the application.
passenger card has the meaning given by subsection 506(2) and, for the purposes of section 115, includes any document provided for by regulations under paragraph 504(1)(c).
Note:Bogus document is defined in subsection 5(1).
98Completion of visa application
A non‑citizen who does not fill in his or her application form or passenger card is taken to do so if he or she causes it to be filled in or if it is otherwise filled in on his or her behalf.
99Information is answer
Any information that a non‑citizen gives or provides, causes to be given or provided, or that is given or provided on his or her behalf, to the Minister, an officer, an authorised system, a person or the Tribunal, or the Immigration Assessment authority, reviewing a decision under this Act in relation to the non‑citizen’s application for a visa is taken for the purposes of section 100, paragraphs 101(b) and 102(b) and sections 104 and 105 to be an answer to a question in the non‑citizen’s application form, whether the information is given or provided orally or in writing and whether at an interview or otherwise.
100Incorrect answers
For the purposes of this Subdivision, an answer to a question is incorrect even though the person who gave or provided the answer, or caused the answer to be given or provided, did not know that it was incorrect.
101Visa applications to be correct
A non‑citizen must fill in or complete his or her application form in such a way that:
(a)all questions on it are answered; and
(b)no incorrect answers are given or provided.
107Notice of incorrect applications
(1)If the Minister considers that the holder of a visa who has been immigration cleared (whether or not because of that visa) did not comply with section 101, 102, 103, 104 or 105 or with subsection (2) in a response to a notice under this section, the Minister may give the holder a notice:
(a)     giving particulars of the possible non‑compliance; and
(b)     stating that, within a period stated in the notice as mentioned in subsection (1A), the holder may give the Minister a written response to the notice that:
(i)if the holder disputes that there was non‑compliance:
(A)shows that there was compliance; and
(B)in case the Minister decides under section 108 that, in spite of the statement under sub‑subparagraph (A), there was non‑compliance—shows cause why the visa should not be cancelled; or
(ii)if the holder accepts that there was non‑compliance:
(A)give reasons for the non‑compliance; and
(B)shows cause why the visa should not be cancelled; and
(c)      stating that the Minister will consider cancelling the visa:
(i)if the holder gives the Minister oral or written notice, within the period stated as mentioned in subsection (1A), that he or she will not give a written response—when that notice is given; or
(ii)if the holder gives the Minister a written response within that period—when the response is given; or
(iii)otherwise—at the end of that period; and
(d)     setting out the effect of sections 108, 109, 111 and 112; and
(e)      informing the holder that the holder’s obligations under section 104 or 105 are not affected by the notice under this section; and
(f)      requiring the holder:
(i)to tell the Minister the address at which the holder is living; and
(ii)if the holder changes that address before the Minister notifies the holder of the Minister’s decision on whether there was non‑compliance by the holder—to tell the Minister the changed address.
(1A)The period to be stated in the notice under subsection (1) must be:
(a)     in respect of the holder of a temporary visa—the period prescribed by the regulations or, if no period is prescribed, a reasonable period; or
(b)     otherwise—14 days.
(1B)Regulations prescribing a period for the purposes of paragraph (1A)(a) may prescribe different periods and state when a particular period is to apply, which, without limiting the generality of the power, may be to:
(a)     visas of a stated class; or
(b)     visa holders in stated circumstances; or
(c)      visa holders in a stated class of people (who may be visa holders in a particular place); or
(d)     visa holders in a stated class of people (who may be visa holders in a particular place) in stated circumstances.
(2)If the visa holder responds to the notice, he or she must do so without making any incorrect statement.
108Decision about non‑compliance
The Minister is to:
(a)consider any response given by a visa holder in the way required by paragraph 107(1)(b); and
(b)decide whether there was non‑compliance by the visa holder in the way described in the notice.
109Cancellation of visa if information incorrect
(1)The Minister, after:
(a)     deciding under section 108 that there was non‑compliance by the holder of a visa; and
(b)     considering any response to the notice about the non‑compliance given in a way required by paragraph 107(1)(b); and
(c)      having regard to any prescribed circumstances;
may cancel the visa.
(2)If the Minister may cancel a visa under subsection (1), the Minister must do so if there exist circumstances declared by the regulations to be circumstances in which a visa must be cancelled.

[2021] AATA 3573

20 August 2021

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Procedural Fairness

Judicial Review

Jurisdiction

Natural Justice

Statutory Construction