2009147 (Refugee)

2009147 (Refugee) [2024] AATA 3859 (22 August 2024)
DECISION RECORD
DIVISION:Migration & Refugee Division
REPRESENTATIVE: Mr Danny Mak (MARN: 0964532)
CASE NUMBER: 2009147

COUNTRY OF REFERENCE: Mauritius
MEMBER:Nicole Burns
DATE:22 August 2024
PLACE OF DECISION: Melbourne
DECISION:The Tribunal affirms the decision not to grant the applicant a protection visa.

Statement made on 22 August 2024 at 4:56pm

CATCHWORDS
REFUGEE – protection visa – Mauritius – particular social group – victim of loan shark – threats from debt collectors – physical assault – attack on home – fear of killing – decision under review affirmed
LEGISLATION
Migration Act 1958, ss 5(1), 5H, 5J – 5LA, 36, 65, 424, 499
Migration Regulations 1994, Schedule 2
CASES
MIAC v SZQRB [2013] FCAFC 33
Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to section 431 of the Migration Act 1958 and replaced with generic information which does not allow the identification of an applicant, or their relative or other dependants.
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 19 May 2020 to refuse to grant the applicant a protection visa under s 65 of the Migration Act 1958 (Cth) (the Act).
The applicant is a citizen of Mauritius. She applied for the visa on 28 June 2016.
The applicant appeared before the Tribunal on 21 August 2024 to give evidence and present arguments. The Tribunal also received oral evidence from her friend, [Friend A], over the telephone.
The Tribunal notes the applicant requested another friend, [Friend B] give witness evidence at hearing. However she did not answer the phone after the Tribunal attempted to call her twice. The Tribunal indicated to the applicant that it would take into account the statutory declaration from [Friend B] that she has provided, in determining her case (considered in more detail below).
The applicant was represented in relation to the review. The representative attended the hearing.
The issues in this case is whether the applicant is refugee or complementary provisions apply (as per the criteria set out below). For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
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 applicant is [an age]-year-old woman from [Village 1] in Mauritius. She first came to Australia [in] April 2008 to study. She claimed protection in Australia based on threats her family continue to receive from loan sharks (and related ‘gang’ members) who purportedly lent her late father money.
The applicant’s claims were initially detailed in the protection visa application in which she claimed, in summary, as follows.
·She came to Australia as a student.
·Her father borrowed money from loan sharks and he feared for her safety as they threatened to harm his family members.
·Her father returned the money and interest but they kept coming to her parents’ house demanding more.
·The gang has threatened her and her family.
·They spray painted their house three times and threatened they could attack her in Australia.
·The gang beat up her father twice and he received many threats.
·The applicant’s father recently passed away due to stress.
·They informed the police but they could not help as there was no evidence the gang had damaged their house and made threats to her family.
In support of the protection visa application the applicant provided to the Department:
·A list of her family members, and her employment, education and travel history.
·A copy of an order from [Court 1] showing the applicant married [in] December 2002 and her divorce was granted [in] January 2011.
·A copy of the applicant’s father’s death certificate showing he died [in] August 2015.
·A copy of a medical certificate dated [in] October 2019 showing the applicant’s brother ([Brother A]) had attended hospital in Mauritius as an outpatient for treatment of [specified injuries].
·A copy of a handwritten report from the Mauritius Police Force stating that on [a day in 2013] the applicant’s father reported receiving threats from unknown individuals that he and his family will be harmed; they came to his house at night and threw rocks at the windows and spray painted around the house; and they fled on motorcycle after beating him and hurting his family.
On 19 May 2020 the delegate refused to grant the applicant a protection visa, not satisfied she was owed protection in Australia. The delegate found the applicant’s evidence at interview[1] about the loan her father had allegedly taken out and related problems from loan sharks in Mauritius vague and lacking details and ultimately did not accept them.
[1] On 11 May 2020
On review the applicant gave oral evidence to the Tribunal about the reasons she continues to fear serious harm on return to Mauritius and her current circumstances. She also provided statutory declarations from two friends[2] from Mauritius who currently reside in Australia, both who attest that the applicant’s family had been threatened and their property vandalised in Mauritius.
[2] From [Friend A] dated 11 August 2024, and [Friend B] dated 11 August 2024.
At hearing the applicant told the Tribunal she remains fearful of being harmed by people whom her father borrowed money from in the past if she has to return to Mauritius. Although her mother told her (over the telephone) in 2012 that her father had repaid his debts, these people kept demanding money from him and threatening him and other family members. She said in addition to threats, they spray painted their family home with black paint several times, beat her father twice, and her brother once.
The applicant said her father reported some of the incidents to the police in Mauritius.
The applicant said her father died of a heart attack in 2015 when [age]: she believes stress related to ongoing threats and harassment from these people contributed to his early death.
The applicant said her [siblings] still receive threats from these people and sometimes give them money.
Findings about the applicant’s claims and future fears
The Tribunal has considered whether the applicant’s father borrowed money from people in Mauritius and experienced threats and harm as a result (along with her brother, [Brother A]).
As discussed at hearing, the Tribunal found the applicant’s oral evidence about her father’s purported loan and problems that ensued vague and lacking in detail. She did not know when he borrowed money, how much, or why. Further she was unclear who he actually borrowed money from. She speculated that he may have borrowed money to help pay for her studies in Australia, but never asked her mother (or [siblings]) specifically about it.
The applicant’s oral evidence about the problems her father and brother ([Brother A]) experienced at the hands of the money lenders (and/or gangs associated with them) was also vague. For example she claimed her father was beaten twice and her brother once but was unsure when this occurred and in what context, including the location. She said her father was injured but was unable to describe his injuries. She was also unsure when the family home was spraypainted and her evidence about how often that occurred changed from a couple of times at the start of the hearing to over three times as the hearing progressed.
The applicant was also vague about more recent threats her brothers allegedly received from money lenders in Mauritius, resulting in them paying them money sometimes. For example she was unable to state when the most recent threat occurred, the nature of the threats, or provide any further details or context.
To explain her lack of knowledge about such matters the applicant noted at hearing that she has been in Australia for 16 years, and her family did not want to worry her. She said they told her more details when she visited Mauritius in 2015 at the time of her father’s funeral. The Tribunal is not persuaded by this explanation because it does not explain why the applicant’s family failed to tell her more details subsequently, particularly given she has claimed protection in Australia on this basis.
Another concern relates to an inconsistency in a significant respect between the applicant’s claims in the protection visa application form that the ‘gang’ had threatened her whereas at hearing she did not indicate that she had ever been threatened by the gang.
The Tribunal also notes the significant delay from when the applicant came to Australia in 2008 and applied for protection in 2016, despite claiming her family had received threats from money lenders prior to that. At hearing the applicant said she came here to study and only when she returned to Mauritius for her father’s funeral in 2015 she became aware of the extent of the problems. However, as noted, the applicant’s evidence about these alleged ongoing problems from money lenders is very vague and lacking in detail.
The applicant’s return visits to Mauritius from Australia in 2015 cast doubt on her claims to fear serious harm from people who her father had borrowed money from. At hearing the applicant said she had to return in 2015 for her father’s funeral. Whilst understandable to some extent, when combined with the other concerns the Tribunal has with the applicant’s case, her return home at this time without any problems adds to its concerns with her core claims.
Given these concerns the Tribunal does not accept the applicant’s father borrowed money from anyone in the past in Mauritius. It follows that it does not accept he continued to receive threats from money lenders in order to obtain more money, even after he had repaid the loan, or that they beat him twice, spray painted his house, or threw rocks at his house. The Tribunal also does not accept the applicant’s brother ([Brother A]) was beaten by these money lenders (or people associated with them) in October 2019 as claimed, or that her brothers continue to receive threats and sometimes give money to those who threaten them, to date, as claimed at haring.
Given these findings the Tribunal also does not accept the applicant’s father reported being threatened, harassed and assaulted by ‘unknown persons’ to the police in 2013 as claimed and indicated in the police report provided to the Department. The police report is handwritten and whilst it includes a date when the applicant’s father purportedly reported the matter, the dates for when he was allegedly beaten, had rocks thrown at his house, and had his house spraypainted are not provided. Given these concerns the Tribunal gives this police report no weight.
Therefore the Tribunal finds the applicant does not face a real chance of serious harm on return to Mauritius from persons who had lent money to her father and continued to pursue him and her brothers for financial gain. Her fears of persecution on this basis are not well founded.
In reaching this conclusion the Tribunal has had regard to the medical certificate the applicant provided to the Department verifying that the applicant’s brother appeared at hospital with injuries [in] October 2019. At hearing the applicant explained her brother obtained this report (and a copy of the police report) after the delegate had requested further information, which he then sent to her.
The Tribunal notes there is no indication in the medical certificate in question about the cause of the applicant’s brother’s injuries. The Tribunal accepts the applicant’s brother may have attended hospital at this time for treatment of [specified injuries] but does not accept these injuries were a result of being beaten by persons who had lent money to their father as claimed, given the concerns the Tribunal has with the applicant’s evidence as discussed.
The Tribunal has also had regard to the written and oral evidence of [Friend A], who is the applicant’s friend from Mauritius (and now in Australia), and the statutory declaration from another friend, [Friend B]. In her statutory declaration [Friend A] attests that the applicant and her family have been through so much with ‘this gang’ that has been threatening their family and vandalising their property. She adds that she knows her family are still worried about the applicant’s welfare because of the constant threats there as she visited them when she went on holidays to Mauritius. In her oral evidence [Friend A] told the Tribunal she is also from Mauritius and knows the applicant and her family there. Like the applicant, she came to Australia to study in 2008. She said she heard from the applicant that someone was threatening her family in Mauritius but she was unsure of the details.
In her statutory declaration [Friend B] states that she has known the applicant for a long time since she was in Mauritius, and she knows back then her house has been vandalised and her family and herself were receiving threats.
The Tribunal notes the written and oral evidence of [Friend A], and the written evidence of [Friend B] is fairly general and appears to be based on what the applicant has told them in terms of her family receiving threats and having their property vandalised by ‘gang’ members. They do not mention the reason for the alleged threats and property damage related to the applicant’s father having borrowed money in the past. At hearing the applicant said she did not share personal stuff about money with her friends.
The Tribunal accepts the applicant may have told these two friends about her family being threatened and subject to property damage in Mauritius as attested by them in their statutory declarations, and in [Friend A’s] case, also at hearing. However their evidence was general and vague and does not overcome the significant concerns the Tribunal has with the applicant’s evidence for reasons discussed above. Accordingly it gives their evidence little weight.
For these reasons the Tribunal finds that the applicant does not face a real chance of persecution on return to Mauritius for any refugee reason in the reasonably foreseeable future and that her fears of persecution are not well-founded.
The Tribunal is not satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 5J of the Act. Therefore the applicant does not satisfy the criterion set out in s 36(2)(a).
COMPLEMENTARY PROTECTION
In considering whether the applicant meets the complementary protection criterion under s 36(2)(aa), the Tribunal has considered whether it has substantial grounds for believing that, as a necessary and foreseeable consequence of the applicant being removed from Australia to her receiving country, there is a real risk that she will suffer significant harm. In this case, the Tribunal accepts the applicant is a national of Mauritius and therefore finds that Mauritius is the ‘receiving country’ for the purposes of s 5(1).
For the reasons set out earlier, the Tribunal does not accept there to be a real chance that the applicant will suffer serious harm if she returns to Mauritius now or in the foreseeable future from anyone as a result of her father borrowing money. In MIAC v SZQRB, the Full Federal Court held that the ‘real risk’ test imposes the same standard as the ‘real chance’ test applicable to the assessment of ‘well-founded fear’ in the Refugee Convention definition.[3] It follows that the Tribunal does not accept there to be a real risk that the applicant will suffer significant harm from anyone for these reasons as a necessary and foreseeable consequence of her being removed from Australia to Mauritius.
[3] MIAC v SZQRB [2013] FCAFC 33 (Lander, Besanko, Gordon, Flick and Jagot JJ, 20 March 2013) per Lander and Gordon JJ at [246], Besanko and Jagot JJ at [297], Flick J at [342].
For these reasons 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 Mauritius there is a real risk she will suffer significant harm.
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.
Nicole Burns
Senior Member

ATTACHMENT - Extract from Migration Act 1958
5 (1) Interpretation
…
cruel or inhuman treatment or punishment means an act or omission by which:
(a)     severe pain or suffering, whether physical or mental, is intentionally inflicted on a person; or
(b)     pain or suffering, whether physical or mental, is intentionally inflicted on a person so long as, in all the circumstances, the act or omission could reasonably be regarded as cruel or inhuman in nature;
but does not include an act or omission:
(c)     that is not inconsistent with Article 7 of the Covenant; or
(d)     arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
degrading treatment or punishment means an act or omission that causes, and is intended to cause, extreme humiliation which is unreasonable, but does not include an act or omission:
(a)     that is not inconsistent with Article 7 of the Covenant; or
(b)     that causes, and is intended to cause, extreme humiliation arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
torture means an act or omission by which severe pain or suffering, whether physical or mental, is intentionally inflicted on a person:
(a)     for the purpose of obtaining from the person or from a third person information or a confession; or
(b)     for the purpose of punishing the person for an act which that person or a third person has committed or is suspected of having committed; or
(c)     for the purpose of intimidating or coercing the person or a third person; or
(d)     for a purpose related to a purpose mentioned in paragraph (a), (b) or (c); or
(e)     for any reason based on discrimination that is inconsistent with the Articles of the Covenant;
but does not include an act or omission arising only from, inherent in or incidental to, lawful sanctions that are not inconsistent with the Articles of the Covenant.
…
receiving country, in relation to a non-citizen, means:
(a)     a country of which the non-citizen is a national, to be determined solely by reference to the law of the relevant country; or
(b)     if the non-citizen has no country of nationality—a country of his or her former habitual residence, regardless of whether it would be possible to return the non-citizen to the country.
…
5H    Meaning of refugee
(1)For the purposes of the application of this Act and the regulations to a particular person in Australia, the person is a refugee if the person is:
(a)     in a case where the person has a nationality – is outside the country of his or her nationality and, owing to a well-founded fear of persecution, is unable or unwilling to avail himself or herself of the protection of that country; or
(b)     in a case where the person does not have a nationality – is outside the country of his or her former habitual residence and owing to a well-founded fear of persecution, is unable or unwilling to return to it.
Note:     For the meaning of well-founded fear of persecution, see section 5J.
…
5J     Meaning of well-founded fear of persecution
(1)For the purposes of the application of this Act and the regulations to a particular person, the person has a well-founded fear of persecution if:
(a)     the person fears being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion; and
(b)     there is a real chance that, if the person returned to the receiving country, the person would be persecuted for one or more of the reasons mentioned in paragraph (a); and
(c)     the real chance of persecution relates to all areas of a receiving country.
Note:     For membership of a particular social group, see sections 5K and 5L.
(2)A person does not have a well-founded fear of persecution if effective protection measures are available to the person in a receiving country.
Note:     For effective protection measures, see section 5LA.
(3)A person does not have a well-founded fear of persecution if the person could take reasonable steps to modify his or her behaviour so as to avoid a real chance of persecution in a receiving country, other than a modification that would:
(a)     conflict with a characteristic that is fundamental to the person’s identity or conscience; or
(b)     conceal an innate or immutable characteristic of the person; or
(c)     without limiting paragraph (a) or (b), require the person to do any of the following:
(i)alter his or her religious beliefs, including by renouncing a religious conversion, or conceal his or her true religious beliefs, or cease to be involved in the practice of his or her faith;
(ii)conceal his or her true race, ethnicity, nationality or country of origin;
(iii)alter his or her political beliefs or conceal his or her true political beliefs;
(iv)conceal a physical, psychological or intellectual disability;
(v)enter into or remain in a marriage to which that person is opposed, or accept the forced marriage of a child;
(vi)alter his or her sexual orientation or gender identity or conceal his or her true sexual orientation, gender identity or intersex status.
(4)If a person fears persecution for one or more of the reasons mentioned in paragraph (1)(a):
(a)     that reason must be the essential and significant reason, or those reasons must be the essential and significant reasons, for the persecution; and
(b)     the persecution must involve serious harm to the person; and
(c)     the persecution must involve systematic and discriminatory conduct.
(5)Without limiting what is serious harm for the purposes of paragraph (4)(b), the following are instances of serious harm for the purposes of that paragraph:
(a)     a threat to the person’s life or liberty;
(b)     significant physical harassment of the person;
(c)     significant physical ill‑treatment of the person;
(d)     significant economic hardship that threatens the person’s capacity to subsist;
(e)     denial of access to basic services, where the denial threatens the person’s capacity to subsist;
(f)     denial of capacity to earn a livelihood of any kind, where the denial threatens the person’s capacity to subsist.
(6)In determining whether the person has a well‑founded fear of persecution for one or more of the reasons mentioned in paragraph (1)(a), any conduct engaged in by the person in Australia is to be disregarded unless the person satisfies the Minister that the person engaged in the conduct otherwise than for the purpose of strengthening the person’s claim to be a refugee.
5K    Membership of a particular social group consisting of family
For the purposes of the application of this Act and the regulations to a particular person (the first person), in determining whether the first person has a well‑founded fear of persecution for the reason of membership of a particular social group that consists of the first person’s family:
(a)     disregard any fear of persecution, or any persecution, that any other member or former member (whether alive or dead) of the family has ever experienced, where the reason for the fear or persecution is not a reason mentioned in paragraph 5J(1)(a); and
(b)     disregard any fear of persecution, or any persecution, that:
(i)the first person has ever experienced; or
(ii)any other member or former member (whether alive or dead) of the family has ever experienced;
where it is reasonable to conclude that the fear or persecution would not exist if it were assumed that the fear or persecution mentioned in paragraph (a) had never existed.
Note:     Section 5G may be relevant for determining family relationships for the purposes of this section.
5L    Membership of a particular social group other than family
For the purposes of the application of this Act and the regulations to a particular person, the person is to be treated as a member of a particular social group (other than the person’s family) if:
(a)     a characteristic is shared by each member of the group; and
(b)     the person shares, or is perceived as sharing, the characteristic; and
(c)     any of the following apply:
(i)the characteristic is an innate or immutable characteristic;
(ii)the characteristic is so fundamental to a member’s identity or conscience, the member should not be forced to renounce it;
(iii)the characteristic distinguishes the group from society; and
(d)     the characteristic is not a fear of persecution.
5LA Effective protection measures
(1)For the purposes of the application of this Act and the regulations to a particular person, effective protection measures are available to the person in a receiving country if:
(a)     protection against persecution could be provided to the person by:
(i)the relevant State; or
(ii)a party or organisation, including an international organisation, that controls the relevant State or a substantial part of the territory of the relevant State; and
(b)     the relevant State, party or organisation mentioned in paragraph (a) is willing and able to offer such protection.
(2)A relevant State, party or organisation mentioned in paragraph (1)(a) is taken to be able to offer protection against persecution to a person if:
(a)     the person can access the protection; and
(b)     the protection is durable; and
(c)     in the case of protection provided by the relevant State—the protection consists of an appropriate criminal law, a reasonably effective police force and an impartial judicial system.
…
36     Protection visas – criteria provided for by this Act
…
(2)A criterion for a protection visa is that the applicant for the visa is:
(a)     a non-citizen in Australia in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee; or
(aa) a non-citizen in Australia (other than a non-citizen mentioned in paragraph (a)) in respect of whom the Minister is satisfied Australia has protection obligations because the Minister has substantial grounds for believing that, as a necessary and foreseeable consequence of the non-citizen being removed from Australia to a receiving country, there is a real risk that the non-citizen will suffer significant harm; or
(b)     a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (a); and
(ii)holds a protection visa of the same class as that applied for by the applicant; or
(c)     a non-citizen in Australia who is a member of the same family unit as a non-citizen who:
(i)is mentioned in paragraph (aa); and
(ii)holds a protection visa of the same class as that applied for by the applicant.
(2A)A non‑citizen will suffer significant harm if:
(a)     the non‑citizen will be arbitrarily deprived of his or her life; or
(b)     the death penalty will be carried out on the non‑citizen; or
(c)     the non‑citizen will be subjected to torture; or
(d)     the non‑citizen will be subjected to cruel or inhuman treatment or punishment; or
(e)     the non‑citizen will be subjected to degrading treatment or punishment.
(2B)However, there is taken not to be a real risk that a non‑citizen will suffer significant harm in a country if the Minister is satisfied that:
(a)     it would be reasonable for the non‑citizen to relocate to an area of the country where there would not be a real risk that the non‑citizen will suffer significant harm; or
(b)     the non‑citizen could obtain, from an authority of the country, protection such that there would not be a real risk that the non‑citizen will suffer significant harm; or
(c)     the real risk is one faced by the population of the country generally and is not faced by the non‑citizen personally.
…

[2024] AATA 3859

22 August 2024

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Statutory Interpretation

Legal Concepts

Judicial Review

Procedural Fairness

Jurisdiction

Standing

Statutory Construction

Appeal