2104981 (Migration)

Case

[2021] AATA 5154

19 November 2021


2104981 (Migration) [2021] AATA 5154 (19 November 2021)

DECISION RECORD

CASE NUMBER:  2104981

DIBP REFERENCE(S):  BCC2019/2525408

MEMBER:Susan Trotter

DATE:19 November 2021

PLACE OF DECISION:  Brisbane

DECISION:The Tribunal affirms the decision not to grant the visa applicant a Partner (Provisional) (Class UF) visa.

Statement made on 19 November 2021 at 3:15pm

CATCHWORDS
MIGRATION –Partner (Provisional) (Class UF) visa – subclass 309 – refugee status – Hazara Shias – not a member of the primary visa applicant’s family unit – suffering from mental health issues –applicant is over 23 years of age at the time of the decision – strong compassionate circumstances – Ministerial intervention referral – decision under review affirmed

LEGISLATION
Migration Act 1958, ss 65, 351, 375
Migration Regulations 1994, rr 1.05, 1.12, Schedule 2, cls 309.321, 309.311

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

  1. This is an application for review of a decision made by a delegate of the Minister for Immigration on 29 March 2021 to refuse to grant the visa applicant a Partner (Provisional) (Class UF) visa under s.65 of the Migration Act 1958 (the Act).

  2. There is a two stage process for Partner visas. Visa applicants must hold a provisional visa in order to be granted a permanent visa. The grant of the provisional visa enables a visa applicant to travel to and remain in Australia on a temporary basis. The grant of a permanent visa may subsequently be considered, and would generally depend on whether the relevant partner relationship has continued for a period of at least two years. When applying from outside Australia, as is relevant to this application, the temporary visa is a Partner (Provisional) (Class UF) visa (a Subclass 309 visa) and the permanent visa is a Partner (Migrant) (Class BC) visa.

  3. Class UF contains only one subclass: Subclass 309 (Partner (Provisional)). The criteria for the grant of this visa are set out in Part 309 of Schedule 2 to the Migration Regulations 1994 (the Regulations). The primary criteria must be satisfied by at least one applicant. Other members of the family unit, if any, who are applicants for the visa need satisfy only the secondary criteria.

  4. On 14 May 2019, Ms [B], as primary visa applicant (the primary visa applicant), applied for a Subclass 309 visa on the basis of her relationship with her sponsor, the review [applicant]. At that time, Class UF contained only one subclass: Subclass 309 (Partner (Provisional). The criteria for the grant of this visa are set out in Part 309 of Schedule 2 to the Migration Regulations 1994 (the Regulations). The primary criteria must be satisfied by at least one applicant. Other members of the family unit, if any, who are applicants for the visa need satisfy only the secondary criteria.

  5. The following persons were included in Ms [B]’s visa application as secondary visa applicants, and identified as the sons and daughters respectively of the primary visa applicant and the review applicant:

    (a)Ms [C] (born [year])

    (b)[Mr A] (born [year])

    (c)Mr [name deleted] (born [year])

    (d)Ms [name deleted] (born [year])

    (e)Ms [name deleted] (born [year])

    (f)Ms [name deleted] (born [year])

  6. On 29 March 2021, the delegate refused to grant visas to Ms [C] and [Mr A]. As regards [Mr A], the delegate’s decision was made on the basis that [Mr A] was not a member of the family unit, as that term is defined, of the primary visa applicant as required. In particular the delegate noted that as [Mr A] was an applicant aged over 23 years of age at the date of decision, consideration was required as to whether r.1.05A(1)(b) was satisfied in relation to him. The delegate concluded that r.1.05A(1)(b) was not met in relation to [Mr A] because he does not have any disability that would prevent him from being unemployed. The delegate therefore concluded that [Mr A] was not a member of the family unit, as that term is defined, of the primary visa applicant such that cl.309.321 of the Regulations was not met as required.

  7. On 19 April 2021, the review applicant lodged an application with the Tribunal seeking review of the delegate’s decision to refuse to grant the visa to [Mr A]. Ms [C] was not included in the application for merits review (as confirmed by the review applicant’s representative in an email of 23 April 2021).

  8. The review applicant appeared in person before the Tribunal on 25 October 2021 to give evidence and present arguments. The Tribunal was assisted by an interpreter in the Hazaragi and English languages.

  9. The review applicant was represented in relation to the review.

  10. For the following reasons, the Tribunal has concluded that the decision under review in relation to [Mr A] should be affirmed.

    ISSUES

  11. [Mr A] seeks to satisfy the secondary criteria for grant of the visa.

  12. The secondary criteria must be satisfied by applicants who are members of the family unit of a person who satisfies the primary criteria. The secondary criteria to be satisfied at the time of application include that the visa applicant is a member of the family unit of, and made a combined application with, a person who satisfies the primary criteria in Subdivision 309.21: cl.309.311. Secondary criteria to be satisfied at the time of decision include that the visa applicant continues to be a member of the family unit of a person who has satisfied the primary criteria: cl.309.321. These clauses state as follows:

    309.3     Secondary criteria

    Note: These criteria must be satisfied by applicants who are members of the family unit of a person who satisfies the primary criteria.

    309.31     Criteria to be satisfied at time of application

    309.311

    The applicant is a member of the family unit of, and made a combined application with, a person who satisfied the primary criteria in Subdivision 309.21.

    309.32     Criteria to be satisfied at time of decision

    309.321

    The applicant:

    (a)   continues to be a member of the family unit of a person who, having satisfied the primary criteria, is the holder of a Subclass 309 (Partner (Provisional)) visa (the person who satisfied the primary criteria); …

  13. Subsection 5(1) of the Act provides that ‘member of the family unit’ has the meaning given by the Regulations made for the purposes of this definition. Regulation 1.03 provides that member of the family unit has the meaning set out in r.1.12.

  14. Since 19 November 2016, and at the date of this visa application[1], r.1.12(2) provides the general rule as to whether a person is a member of the family unit of another person (called ‘the family head’) as follows:

    [1] The Tribunal notes that r.1.12 was amended in relation to visa applications made on or after 19 November 2016. As the visa application the subjection of this application to the Tribunal was made on 14 May 2019, the post 19 November 2019 version applies.

    (2)      A person is a member of the family unit of another person (the family head) if the person:

    (a)is a  or de facto partner of the family head; or

    (b)is a child or step-child of the family head or of a spouse or de facto partner of the family head (other than a child or step-child who is engaged to be married or has a spouse or de factor partner) and:

    (i)     has not turned 18; or

    (ii)has turned 18, but has not turned 23, and is dependent on the family head or on the spouse or de facto partner of the family head; or

    (iii)     has turned 23 and is under paragraph 1.05A(1)(b) dependent on the family head or on the spouse or de facto partner of the family head; or

    (c)is a dependent child of a person who meets the conditions in paragraph (b).

    This subregulation has effect subject to later subregulations of this regulation.

  15. Subclauses (3) to (7) of r.1.12 set out provisions relevant to circumstances not applicable to this visa application.

  16. Regulation 1.05A(1)(b) relevantly provides as follows:

    (1)Subject to subregulation (2), a person (the first person) is dependent on another person if:

    (a)at the time when it is necessary to establish whether the first person is dependent on the other person:

    (i)  the first person is, and has been for a substantial period immediately before that time, wholly or substantially reliant on the other person for financial support to meet the first person’s basic needs for food, clothing and shelter; and

    (ii) the first person’s reliance on the other person is greater than any reliance by the first person on any other person, or source of support, for financial support to meet the first person’s basic needs for food, clothing and shelter; or

    (b)the first person is wholly or substantially reliant on the other person for financial support because the first person is incapacitated for work due to the total or partial loss of the first person’s bodily or mental functions.

  17. Subregulation (2) relates to protection, refugee and humanitarian visas and is not applicable to this visa application, a partner visa application.

  18. It is not in dispute that [Mr A] was born in [year] and is therefore now [age] years of age.

  19. It follows that the issues to be determined by the Tribunal are:

    (a)Was [Mr A] a member of the family unit of the primary visa applicant at the time of the visa application? And, if so,

    (b)Did [Mr A] make a combined application with a person who satisfies the primary criteria? And, if so,

    (c)Does [Mr A] continue to be a member of the family unit of the primary visa applicant now at the time of decision?

    CONSIDERATION OF CLAIMS AND EVIDENCE

  20. The review applicant’s representative’s acknowledged at hearing that [Mr A] has turned 23 years of age since the time of the visa application, that the visa application was made after the commencement of amendments to the Regulations which, in relation to visa applications of this type, excludes persons aged over 23 years of age from the definition of ‘member of the family unit’ (unless r.1.05A(1)(b) is satisfied). However, the review applicant’s representative submitted at hearing that a wider view should be taken or more flexibility should be given, including recognition of the compelling and compassionate circumstances in relation to [Mr A] because he is a refugee in [Country 1] with no visa status who cannot go back to his home country of Afghanistan because he is a Hazara and Hazaras are highly persecuted in Afghanistan.

  21. In written submissions, the review applicant’s representative sought that the Tribunal remit the application on the basis that cl.309.311 and cl.309.321 are met. It was submitted that the power of the Tribunal should go beyond the law, including because of individual cases of which the representative is aware where the Department itself has sometimes applied the pre-19 November 2016 definition of member of a family unit, even in relation to matters which relate to applications made after the definition was changed. The review applicant’s representative sought that, failing a remittal on the basis that the necessary criteria at law are met, that the Tribunal recommend the matter for Ministerial Intervention.

  22. The 15 October 2021 written submissions, and associated documentary evidence before the Tribunal, includes as follows:

    (a)  It is submitted that [Mr A] is a member of the primary visa applicant’s family unit on the grounds of him being a member of her family unit, his humanitarian situation and no other visa options being available to him’.

    (b)  [Mr A] was [age] years old at the time of application and was wholly or substantially reliant on the review applicant and the primary visa applicant for financial support to meet his basic needs. The review applicant would send money to the primary visa applicant and her family, including [Mr A], which they used to meet their basic needs (as evidenced by documents provided to the Tribunal including copies of money orders). [Mr A]’s reliance on this support was greater than the support he received from any other source.

    (c)   [Mr A] continues to be a member of the primary visa applicant’s family unit and dependent on his father, the review applicant, and receives money from him including as evidenced by money transfers on 29 June 2021 ($1,000), 3 August 2021 ($1,000), 7 September 2021 ($935.34) and 2 October 2021 ($936.01) to meet his needs.

    (d)  The visa applicant does not work in [Country 1]. He experiences mental health problems as a result of the partner visa refusal, the prospect of being left alone in [Country 1] and the unstable situation it has left him in. As a result, the visa applicant is wholly or substantially reliant on the review applicant and the primary visa applicant for financial support to meet his basic needs.

    (e)  The visa applicant was refused a partner visa because he had turned 23 [before] the (delegate’s) decision. If the decision was made [earlier], [Mr A] would have been included in the primary visa applicant’s family unit under r.1.12(2)(b)(ii).

    (f)    If the visa applicant is refused the visa on the basis of him not being a member of the primary visa applicant’s family unit, it will produce an unfair outcome and not recognise the applicant’s true dependency on his family. The visa applicant was [age] years old at the time of the application, and barely 23 years old at the time of the original (delegate’s) decision.

    (g)  Visas have been granted by the Department to other visa applicants from Afghanistan in a similar position to [Mr A], that is children of primary visa applicants who have turned 23 years of age since the time of visa applications (made after 19 November 2016), and who are not incapacitated for work due to total or partial loss of their bodily or mental functions. If the regulations were strictly followed, these other individuals would not have been granted visas such that it appears there is some discretion to grant partner visas to secondary applicants, even if they do not strictly meet the requirements under the Regulations, and this should be used in [Mr A]’s favour.

    (h)  [Mr A] should still be considered a member of the primary visa applicant’s family unit particularly in light of his humanitarian situation and the limited visa options available to him. [Mr A] is Hazara Shia, resides in [Country 1] as a refugee and is registered with the UNHCR. [Mr A] has no legal status, no permanent settlement options and no work rights in [Country 1]. A letter from the United Nations High Commissioner for Refugees dated 5 August 2021 includes as follows:

    This is to certify that Mr. [A] (DOB: [year]) from Afghanistan, is an asylum-seeker registered with the Office of the United Nations High Commissioner for Refugees. This person’s claim for refugee status is in the process of being examined. As an asylum-seeker, he is a person of concern to the Office of the United Nations High Commissioner for Refugees, and should, in particular, be protected from forcible return to a country where he claims to face threats to his life or freedom, pending a final decision on his refugee status…

    (i)    The primary visa applicant and [Mr A]’s younger siblings will soon reside in Australia with the review applicant. Ms [C] has married since the time of the visa application and is not pursuing the visa.

    (j)    The visa refusal has taken its toll on [Mr A]’s mental health and he has been receiving mental health treatment since April 2021 with a report from [a hospital] on 21 April 2021 noting:

    … [The visa applicant] was referred from ED for depressive symptoms for 2 weeks, associated with difficulty to sleep with on and off crying spells.

    Patient mentioned that his stressor is father far away from him, his own Visa was rejected.

    Patient feel depressed past 2 weeks as his father who is working in Australia however his Visa and also the elder sister’s was rejected. He is currently living her with his mother, younger brother, and younger sister.

    Patient is worried about his future, having poor sleep, associated with reduced appetite.

    Otherwise, no delusions, no hallucinations, not suicidal, no deliberate self harm

    (k)   [Mr A] has since been diagnosed with adjustment disorder with depressed mood with a report of Dr [D] of [a named hospital], [Country 1], dated 25 May 2021 including as follows:

    Patient came with his translator, still feeling sad because of his previous stressor. Patient claimed he will be alone here if all [his] family go to Australia later. Depressive symptoms worsening as patient preferred to stay alone now as he did not want to meet his friends as he feels he is sick, did not want them to see him in this poor condition.

    Sleep still depends on medication. Patient will cry whenever the thinks of issues. Patient feels hopeless but no passive death wishes, no active suicidal ideation.

    (l)    [Mr A] receives regular follow up mental health treatment. In light of his mental health, particularly as a refugee in [Country 1] who remains there temporarily and does not have a work permit, he should be recognised as a member of the primary visa applicant’s family unit.

    (m) There are further humanitarian grounds in this case because [Mr A] cannot return to Afghanistan due to the current security situation and his status as a refugee. During the Taliban previous regime from 1996 to 2001, human right groups documented three large-scale massacres of Hazara civilians. Hazara Shias faced particularly severe repression and persecution during this time and the Taliban declared jihad against them. The violence against Hazaras continued after the fall of the Taliban in 2001, with travellers between Hazara-dominated Bamiyan and Kabul often pulled from buses and killed. The targeting of Hazara by the Taliban after their recent takeover has been reported. In August 2021, the Taliban murdered 13 ethnic Hazara people according to Amnesty International. The Islamic State – Khorasan Province has also targeted Hazara Shias in recent years. Now that the Taliban has returned to power, Hazara Shias fear that they will again be subjected to the persecution they experienced under the Taliban during their previous regime. Therefore, returning to Afghanistan is not an option for the visa applicant.

    (n)  In light of [Mr A]’s health, status as a refugee in [Country 1] and his inability to return to Afghanistan, he is vulnerable and dependent upon his family. His humanitarian situation necessitates that he be considered a member of the primary visa applicant’s family unit.

    (o)  There are no other suitable visa options open to [Mr A].

    (p)  The current situation in Afghanistan means there is increased demand for humanitarian visas to Australia. With no increase in the humanitarian intake, it is very unlikely [Mr A] will be granted a humanitarian visa in the foreseeable future, despite his need for a permanent settlement option and vulnerability as a Hazara Shia, due to the large number of humanitarian visa applications from similarly vulnerable Afghan nationals.

  23. The review applicant’s evidence to the Tribunal includes as follows:

    (a)  He first arrived in Australia in 2011.

    (b)  When the Taliban came to his family’s area of Afghanistan in 2000, they were looking for people of interest and he was one of the people that were forced to help. He resisted and did not want to help but was forced to help. He was going to be forced to go to the front line and kill civilians. When it was his turn to do this, he fled and escaped to Iran. He and his family left Afghanistan and lived in Iran for 10 years. However, they were deported from Iran after 10 years and came back to Afghanistan. After he returned to Afghanistan, the Taliban regime had collapsed and the Mujahideen were in power. However, when he returned to Kabul, he was being pursued and left for Pakistan.

    (c)   Since he arrived in Australia in 2011, his family were in Kabul and then have been living in [Country 1] for the last three years. His wife and his younger children have now been granted visas but they have not yet come to Australia, including because they have not wanted to leave [Mr A] there by himself. He provides all financial support to his family in [Country 1].

    (d)  He is suffering from mental health issues and is taking medication for these issues. The refusal of [Mr A]’s visa has had a very significant adverse effect on his family, himself and his wife and their mental health.

    Issue 1 - Was [Mr A] a member of the family unit of the primary visa applicant at the time of the visa application?

  1. The Tribunal is satisfied on the evidence before it that at the time of the visa application on 14 May 2019, [Mr A] was a child of both the primary visa applicant and her spouse, the review applicant, and he had turned 18 but had not turned 23. Further, the Tribunal is satisfied on the evidence before it that [Mr A] was, as at 14 May 2019, dependent on the primary visa applicant, or her spouse, the review applicant, and had been for a substantial period immediately before that time for financial support to meet his basic needs for food, clothing and shelter. Further, the Tribunal is satisfied that [Mr A]’s reliance on the primary visa applicant, or her spouse, the review applicant, was greater than his reliance on any other person or any other source of support. Regulation 1.12(b)(ii) was therefore met at the time of the visa application in relation to [Mr A].

    Issue 2 - Did [Mr A] make a combined application with a person who satisfies the primary criteria?

  2. The Tribunal is satisfied on the evidence before it that [Mr A] made a combined application with the primary visa applicant who satisfies the primary criteria.

    Issue 3 - Does [Mr A] continue to be a member of the family unit of the primary visa applicant now at the time of decision?

  3. To continue to be a member of the family unit of the primary visa applicant now at the time of decision, [Mr A] must meet either clause (i), (ii) or (iii) of r.1.12(2)(b) now at the time of decision. As [Mr A] is now [age] years of age, he does not meet clauses (i) or (ii). The Tribunal therefore considered whether r.1.12(2)(b)(iii) is satisfied. That provisions requires that [Mr A], under paragraph 1.05A(1)(b), is dependent on the family head or on the spouse or de facto partner of the family head. To meet r.1.05A(1)(b), [Mr A] must now, at the time of decision, be wholly or substantially reliant on the primary visa applicant (or her spouse, the review applicant) for financial support because [Mr A] is incapacitated for work due to the total or partial loss of the first person’s bodily or mental functions[2].

    [2] Tribunal emphasis added.

  4. The Tribunal has had regard to the medical reports in evidence from the Hospital [and] Dr [D] and acknowledges that [Mr A]’s mental health is currently, and understandably, adversely impacted due to his visa situation. However, there is no evidence before the Tribunal that [Mr A] is incapacitated for work due to the total or partial loss of his bodily or mental functions. The Tribunal is therefore not satisfied that r.1.12(2)(b)(iii) is met.

  5. As none of clauses (i), (ii) or (iii) of r.1.12(2)(b) are met, [Mr A] is not a member of the family unit of either the primary visa applicant or her spouse, the review applicant, now at the time of decision.

  6. The Tribunal recognises all of the circumstances addressed by the review applicant and his representative, including in written evidence and submissions before the Tribunal, and canvassed in the oral evidence and oral submissions at hearing. However, there is nothing in the Act or the Regulations that enables the Tribunal to consider these circumstances in determining whether the required criterion in the Regulations is met.

  7. [Mr A] is over 23 years of age now at the time of the decision, and, as already canvassed, there is no evidence before the Tribunal that he is incapacitated for work. There is no ambiguity in the relevant legislative provisions and the Tribunal has no power to change the law. The Tribunal must find that the applicant does not satisfy r.1.05A(1)(b) and consequentially is not a member of the family unit of either the primary visa applicant or the review applicant pursuant to r.1.12 now at the time of decision as required. It follows that [Mr A] does not continue to be a member of the family unit of the primary visa applicant as required for cl.309.321 to be met as required. Clause 309.321 is not satisfied in relation to [Mr A].

  8. For the reasons above, [Mr A] does not satisfy the criteria for the grant of the visa and the decision under review must be affirmed.

    OTHER MATTERS

  9. The Tribunal notes that the Department’s file contains a s.375A certificate dated 3 May 2021 relating to certain information on its file.

  10. The Tribunal raised the issue of the s.375A certificate with the applicant’s representative at hearing and noted that the Tribunal considered the information the subject of the certificate of no relevance to the issues before it. After the hearing, the Tribunal provided the applicant’s representative with a copy of the certificate and allowed until 8 November 2021 for submissions to be made in relation to the certificate, including its validity. No submissions were received in relation to the certificate. The Tribunal considers the certificate to be valid however, as discussed at hearing, does not consider the information to which the certificate relates of any relevance to the issues before the Tribunal and has had no regard to that information in reaching its decision.

  11. The Tribunal also acknowledges the applicant’s representative’s submissions in relation to other matters where the Department has found favourably for persons in a similar situation to [Mr A]. However, the Tribunal must consider the application before it based upon its own individual circumstances and must follow the law as enacted.

    MINISTERIAL INTERVENTION

  12. The review applicant has requested that the Tribunal refer the case to the Department for consideration by the Minister if a favourable decision cannot be made in relation [Mr A].

  13. Section 351 of the Act provides that, if the Minister thinks that it is in the public interest to do so, the Minister may substitute for a decision of the Tribunal another decision, being a decision that is more favourable to an applicant, whether or not the Tribunal had the power to make that other decision. In deciding whether to refer the matter to the Minister for consideration under s.351, the Tribunal has had regard to the President’s Direction on Conducting Migration and Refugee Reviews dated 1 August 2018, especially at paragraphs 16.1–16.7 concerning referrals for ministerial intervention and the Minister’s Guidelines on ministerial powers (s.351, s.417, and s.501J) available in the Procedures Advice Manual 3 (the Minister’s Guidelines).

  14. Among other things, the Minister’s Guidelines state that the Minister may consider exercising his or her discretion in cases that exhibit one or more ‘unique or exceptional circumstances’. The Guidelines then identify factors that may be relevant, individually or cumulatively, in assessing whether a case involves unique or exceptional circumstances. Without limiting the scope of the consideration, the Tribunal considers the following unique and/or exceptional circumstances to be relevant in this case:

    (a)  Compassionate circumstances regarding the age and/or health and/or psychological state of the person that if not recognised would result in serious, ongoing and irreversible harm and continuing hardship to the person.

    (b)  Strong compassionate circumstances that if not recognised would result in serious, ongoing and irreversible harm and continuing hardship to an Australian citizen or an Australian family unit, where at least one member of the family is an Australian citizen or Australian permanent resident.

    (c)   The person cannot be returned to their country/countries of citizenship or usual residence due to circumstances outside their control.

  15. Based on the medical evidence, the Tribunal is satisfied that there are compassionate circumstances regarding the psychological state of [Mr A] that if not recognised would result in serious, ongoing and irreversible harm and continuing hardship to him if he was forced to remain in [Country 1] whilst his parents and younger siblings are in Australia. This is particularly in circumstances where he has been recognised by the United Nations Commission on Human Rights as being an asylum-seeker. Notably, following the withdrawal of coalition forces from Afghanistan on 31 August 2021[3] and Afghanistan falling to the Taliban, the security situation in Afghanistan is uncertain and reports are consistent with further and continuing targeting of Hazaras[4] such that [Mr A] is unlikely to be able to safety return to his country of citizenship. The Tribunal is further satisfied that there are strong compassionate circumstances that if not recognised would result in serious, ongoing and irreversible harm and continuing hardship to the review applicant, an Australian permanent resident, and his family unit, if [Mr A] was forced to live apart from his parents and younger siblings.

    [3] ‘Afghanistan: Taliban unlawfully killed 13 ethnic Hazara people, Amnesty says’, British Broadcasting Company (online, 5 October 2021) < and Jill Gralow, ‘Fears abroad for fate of Hazara minority as Taliban take control’, Reuters (online, 17 August 2021)

    [4] >

    The Tribunal is further satisfied that none of [Mr A]’s circumstances fall within the ‘inappropriate to consider’ circumstances canvassed in the Minister’s guidelines.

  16. Having regard to circumstances identified, the Tribunal has decided to refer the matter for consideration of Ministerial intervention.

    decision

  17. The Tribunal affirms the decision not to grant the visa applicant a Partner (Provisional) (Class UF) visa.

    Susan Trotter
    Member




and Amy Kazmin, Najmeh Bozorgmehr and Farhan Bokhari, ‘Afghanistan’s Shia are fearful in face of Taliban takeover’,
Financial Times (online, 26 August 2021) <

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