2008660 (Refugee) v Minister for Immigration and Multicultural Affairs

2008660 (Refugee) [2024] ARTA 871 (13 December 2024)

Respondent: Minister for Immigration and Multicultural Affairs

Tribunal Number: 2008660

Tribunal: Alexandra Stratigos

Date: 13 December 2024

Place: Brisbane

Decision: The Tribunal affirms the decision under review.

Statement made on 13 December 2024 at 12:32pm

CATCHWORDS

REFUGEE – protection visa – Vietnam – political opinion – opposition to the government – freedom of expression – social media activism – human rights – threats to family – state protection – decision under review affirmed

LEGISLATION

Administrative Review Tribunal Act 2024, s 105
Migration Act 1958, ss 5(1), 5AAA, 5H, 5J – 5LA, 36, 65, 499
Migration Regulations 1994, Schedule 2

CASES

MIAC v SZQRB (2013) 210 FCR 505

Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 369 of the Migration Act 1958 and replaced with generic information.

Statement of reasons

APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 15 May 2020 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 national of Vietnam, applied for the visa with the Department of Home Affairs (the Department) on 23 June 2019. On 15 May 2020 the Department refused to grant the visa and he sought a review of that decision with the Tribunal on 23 May 2020. The delegate refused to grant the visa having found that the applicant does not face a real chance of persecution on return to Vietnam nor a real risk that the applicant would face significant harm if returned to Vietnam.
The applicant did not attend a hearing and has requested that his matter be determined on material available before the Tribunal.
MAKING A DECISION WITHOUT A HEARING
On 31 October 2024 the Tribunal wrote to the applicant advising that his matter was being prepared to be constituted to a Member and requested that the applicant complete a pre-hearing information form. On 7 November 2024 the Tribunal received by email a form MR6 notifying the Tribunal of a change in address and appointing an authorised recipient, on 15 November the Tribunal received a form MR5 appointing the recipient to also be the representative; these emails were sent from the newly appointed representative.
On 22 November 2024 the Tribunal received a completed pre-hearing information form from the authorised representative which was signed by the applicant and stated:
“Due to personal reasons, I will not be able to attend any hearings
Please base on information provided in my initial claims to process my review application.” (sic)
On 2 December 2024 the Tribunal wrote to the applicant, via email to the appointed representative, inviting the applicant to attend a hearing to give evidence and present arguments at 10am (QLD time) on 18 December 2024. In the hearing invitation it states:
Please note that if you request the Tribunal to make a decision without a hearing, and the Tribunal proceeds to make a decision because it considers the issues can be determined in your absence, this does not guarantee you will receive a favourable decision.
On 2 December 2024 the Tribunal received from the applicant a response to the hearing invitation, via email from the appointed representative, which attached the completed hearing response form; the form was signed by the applicant on 2 December 2024. The first question on the form asks: “Will you take part in the hearing scheduled for 18 December 2024? (Please indicate ‘Yes’ or ‘No’ for each review applicant).” The applicant left the ‘yes’ box blank and marked an X in the box marked: “No, I will not participate in the hearing, and request the Tribunal to make a decision on the papers without holding a hearing.”
On 3 December 2024 the Tribunal wrote to the applicant, via their appointed representative, to confirm receipt of hearing response form, acknowledge that they had asked for a decision
on the papers, and to vacate the scheduled hearing. The Tribunal also informed the applicant that it would proceed to make a decision on the material available before it.
Section 106(3) of the Administrative Review Tribunal Act 2004 (ART Act) sets out the circumstances in which the Tribunal may reach a decision in relation to a review of a decision to refused to grant a protection visa without a hearing. These circumstances included where: the applicant request that the Tribunal do so, and where “it appears to the Tribunal that the issues for determination in the proceeding can be adequately determined in the absence of the parties to the proceedings.”
In this case the Tribunal is satisfied that the applicant has requested that the Tribunal determine the matter without holding a hearing and that s106(3)(b)(ii) of the ART Act can be met. The applicant made this request in both the completed hearing response form and also in the pre-hearing information form; both of which were signed by the applicant.
The Tribunal must also consider whether the issues for determination in the proceedings can be adequately determined in the absence of the applicant. In this matter the issues for determination are whether the applicant satisfies s36(2)(a) or (aa) and is owed protection as a refugee or under the complementary protection framework
In this case the applicant has been provided with an opportunity to present his case. He was asked by the Department in the acknowledgement of application to provide all the information that he felt was relevant. The delegate highlighted their concerns regarding his claims in their decision. The Tribunal also asked the applicant to provide any materials that he wished the Tribunal to consider, he was told to do this on three separate occasions, being in the letter acknowledging lodgement of the application with the Tribunal, in the pre-hearing information form and also in the hearing invitation form and correspondence. The applicant also declined the invitation to attend a hearing. In these circumstances the Tribunal finds that the applicant does not have anything further to present in relation to his claims, having been given a fair opportunity to provide further information, evidence and submissions.
The Tribunal is satisfied in this case that the issues can be adequately determined in the absence of the applicant attending a hearing. The Tribunal has the applicant’s initial protection visa application where he outlined the reasons why he feels he is owed protection; the Tribunal notes that each of the questions in the application under the heading ‘Reasons for claiming protection’ have been completed. The applicant also submitted a copy of the bio data page of their passport and the visa grant notification for the visa that they held to enter Australia. The applicant also provided to the Tribunal a copy of the decision of the delegate refusing to grant the applicant the protection visa. For the purpose of this review the Tribunal can therefore determine applicant’s identity, the relevant country of reference and receiving country. The Tribunal can also assess whether or not the applicant satisfies s36(2)(a) or 36(2)(aa) based upon the claims for protection outlined by the applicant in the application that they submitted to the Department.
BACKGROUND
The applicant claims to be [an age]-year-old man from Vietnam. He arrived in Australia on student visa that was granted in early 2015 and was valid until 15 March 2019. He was [age] years old at the time of his arrival in Australia.
CLAIMS AND EVIDENCE
Evidence before the Department
In support of the applicant’s protection visa application the applicant submitted to the Department his protection visa application, the student visa grant notification and a copy of the bio-data page of his Vietnamese passport.
The Tribunal also has available the delegate’s decision. The delegate’s decision reveals that the applicant was not invited to attend an interview.
In the application for the protection visa the applicant claims to be a single man from Vietnam. He claims that he was born in Ha Noi. He has two living parents, [and specified family members] and they all reside in Vietnam. The applicant claims to have resided at one address in Ha Noi since birth up until his departure to come to Australia.
The applicant claims to have never had any employment prior to lodging the protection visa. He completed secondary school in [specified year], and [later] travelled to Australia where he has been studying and claims that the highest level of education is a [Qualification 1], which he obtained in Australia at the end of 2018. The applicant came to Australia as he claims that his family had decided it would be a good idea for the applicant to study abroad. He departed Vietnam lawfully as the holder of a valid passport and a valid visa for entry into Australia.
The applicant had not faced any harm in Vietnam prior to travelling to Australia. It was when in Australia that the applicant claims that he realised that in Vietnam there are no human rights and people have a lack of freedom to express themselves.
The applicant claims that since being in Australia he has been expressing his opinion on social media, his opinion being that in Vietnam it is unfair that people do not have a right to express their thoughts safely. The applicant claims that since making these social media posts people have been looking for him and threating his family and this has made him feel unsafe to return home.
The applicant claims that if he is returned to Vietnam people may pay money to a group of people to try to find him and harm him.
The applicant claims that the authorities in Vietnam cannot protect him as people need to pay a high price to be able to be protected by the authorities. He claims that he cannot relocate within Vietnam to avoid harm as he would face the same risks throughout Vietnam.
Evidence before the Tribunal
The applicant did not provide to the Tribunal any further information in support of this claims.
CONSIDERATION OF CLAIMS AND EVIDENCE
Criteria for 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.
REASONS AND FINDINGS
The issue in this case is whether the applicant is owed protection as a refugee or under the complementary protection provisions. For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
Background and Identity
The applicant claims to be a citizen of Vietnam and has provided a copy of his passport, on this basis, and with no information available to the contrary, for the purposes of assessing whether the applicant is owed protection the Tribunal accepts that the applicant is a national of Vietnam. The Tribunal is finds that the country of reference is Vietnam.
The Tribunal accepts that the applicant is [an age] year old man from Ha Noi who departed Vietnam lawfully on a valid passport, and entered Australia on a valid student visa for the purposes of engaging in studies at [age].
Does the applicant satisfy the refugee criterion for protection?
The applicant claims to have realised after he came to Australia that his ability to express himself freely in Vietnam was limited and that Vietnam lacked human rights; he then claims to have commenced making posts on social media about this realisation. The applicant claims that his social medial posts attracted attention in Vietnam which resulted in people looking for him and threatening him and his family.
The applicant has not provided copies of any social media posts. The applicant has not indicated what was located in any of the alleged social media posts. The applicant has not provided specific details as to what his opinions on human rights and freedom of speech are or how or why his views may have attracted attention of ‘people’ in Vietnam. The applicant has also not provided further detail about how he and his family were threatened, what the threats entailed, or who threatened them. He has only indicated that ‘people went looking for me threatening my family in a way that I feel unsafe to return home’.
Section 5AAA of the Act provides that it is responsibility of the applicant to “specify all particulars of his or her claim to be such a person to provide sufficient evidence to establish the claim.” This section also provides that the Tribunal “does not have any responsibility or obligation to: (a) specify, or assist in specifying, any particulars of the [applicant’s] claim or (b) establish, or assist in establishing, the claim. The Tribunal has applied s 5AAA when considering the applicant’s claims and evidence and for the reasons already outlined above considers the applicant to have been given sufficient opportunities to specify the particulars of his claims and provide sufficient evidence, and the Tribunal concluded that the applicant has no further particulars or evidence to offer.
For these reasons, specifically the lack of evidence of any social media posts or details as to the contents and frequency of such posts, and the vague and general evidence relating to any political opinions he may have and any threats received, the Tribunal does not accept that the applicant posted his opinions regarding freedom of speech and/or human rights on social media, expressed those opinions in any other means or has opinions on freedom of speech and/or human rights which may attract negative attention in Vietnam. The Tribunal also does not accept that people have been looking for him and/or have threatened him or his family as claimed.
The Tribunal notes that the applicant has not claimed that he or his family have faced any harm in the past, the applicant has also not identified any other reasons in his application other than those cited above which cause him to fear harm if returned or resulted in him choosing to lawfully depart Vietnam for the purposes of pursuing higher education. The Tribunal also notes that the applicant has not claimed to have any other political opinions beyond the views outlined above relating to freedom of speech and human rights.
On the basis of the aforementioned findings the Tribunal finds that the applicant can return to Ha Noi, Vietnam, where his family reside. The Tribunal finds that he will not be harmed by the government or anyone else for any reason.
The Tribunal finds that the applicant does not face a real chance of serious, or any, harm if returned to Vietnam on the basis of his political views/opinions in relation to human rights and/or lack of freedom of speech or for any other reason. The Tribunal therefore finds that the applicant does not have a well-founded fear of persecution on the basis of his political opinions and is not satisfied that he is a refugee as per s 36(2)(a) of the Act.

Does the applicant satisfy the complementary protection criterion for protection?

Having concluded that the applicant does not meet the refugee criterion in s 36(2)(a), the Tribunal has considered the alternative criterion in s 36(2)(aa).
Section 36(2)(aa) refers to a ‘real risk’ of an applicant suffering significant harm. In MIAC v SZQRB (2013) 210 FCR 505, the ‘real risk’ test was held to impose the same standard as the ‘real chance’ test applicable to the assessment of ‘well-founded fear’ in the Refugee Convention definition, and that reasoning appears equally applicable to the refugee criterion in s 5J(1)(b) of the Act (see Explanatory Memorandum, Migration and Maritime Powers Legislation Amendment (Resolving the Asylum Caseload Legacy) Bill 2014 (Cth), pp.170-1 at [1169], [1180]). As the Tribunal has found that the applicant does not face a real chance of any harm for any reason, it follows that the Tribunal does not accept that there is a real risk that the applicant would face significant harm if returned to Vietnam.
For the reasons given above the Tribunal is not satisfied that there are substantial grounds for believing that as a necessary and foreseeable consequence of the applicant being removed from Australia to Vietnam, there is a real risk that the applicant will suffer significant harm. The Tribunal is therefore not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(aa) of the Act.
CONCLUSION
For the reasons given above, the Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(a).
Having concluded that the applicant does not meet the refugee criterion in s 36(2)(a), the Tribunal has considered the alternative criterion in s 36(2)(aa). The Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(aa).
There is no suggestion that the applicant satisfies s 36(2) on the basis of being a member of the same family unit as a person who satisfies s 36(2)(a) or (aa) and who holds a protection visa. Accordingly, the applicant does not satisfy the criterion in s 36(2).
DECISION

The Tribunal affirms the decision not to grant the applicant a protection visa.

ATTACHMENT - Extract from Migration Act 1958

5 (1) Interpretation

...

cruel or inhuman treatment or punishment means an act or omission by which:

(a)    severe pain or suffering, whether physical or mental, is intentionally inflicted on a person; or
(b)   pain or suffering, whether physical or mental, is intentionally inflicted on a person so long as, in all the circumstances, the act or omission could reasonably be regarded as cruel or inhuman in nature; but does not include an act or omission:
(c)    that is not inconsistent with Article 7 of the Covenant; or
(d)   arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the
Articles of the Covenant.

...

degrading treatment or punishment means an act or omission that causes, and is intended to cause, extreme humiliation which is unreasonable, but does not include an act or omission:

(a) that is not inconsistent with Article 7 of the Covenant; or
(b) that causes, and is intended to cause, extreme humiliation arising only from, inherent in or incidental
to, lawful sanctions that are not inconsistent with the Articles of the Covenant.

...

torture means an act or omission by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person:

(a)    for the purpose of obtaining from the person or from a third person information or a confession; or
(b)   for the purpose of punishing the person for an act which that person or a third person has committed or is suspected of having committed; or
(c)    for the purpose of intimidating or coercing the person or a third person; or
(d)   for a purpose related to a purpose mentioned in paragraph (a), (b) or (c); or
(e)    for any reason based on discrimination that is inconsistent with the Articles of the Covenant;
but does not include an act or omission arising only from, inherent in or incidental to, lawful sanctions that
are not inconsistent with the Articles of the Covenant.

...

receiving country, in relation to a non-citizen, means:

(a) a country of which the non-citizen is a national, to be determined solely by reference to the law of the relevant country; or
(b) if the non-citizen has no country of nationality—a country of his or her former habitual residence,
regardless of whether it would be possible to return the non-citizen to the country.

...

5H Meaning of refugee

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

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.
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.
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.
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.
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.
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

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.
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.

...

Protection visas – criteria provided for by this Act
...
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.

...

[2024] ARTA 871

13 December 2024

Key Legal Topics

Areas of Law

Immigration & Refugee Law

Legal Concepts

Refugee Status

Fear of Persecution

Protection Visa

Judicial Review

Human Rights