2320868 (Refugee)

2320868 (Refugee) [2024] AATA 3367 (4 July 2024)
DECISION RECORD
DIVISION:Migration & Refugee Division
CASE NUMBER:  2320868
COUNTRY OF REFERENCE:                   Tonga
MEMBER:Jessica Henderson
DATE:4 July 2024
PLACE OF DECISION:  Perth
DECISION:The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(aa) of the Migration Act.

Statement made on 04 July 2024 at 8:47am
CATCHWORDS
REFUGEE – protection visa – Tonga – religion – converted from Islam to Mormon – economic claims – complementary protection – family violence – gender-based violence – discriminatory allocation of household roles to women and youngest children – decision under review remitted
LEGISLATION
Migration Act 1958 (Cth), ss 5H, 5J, 36, 65
Migration Regulations 1994 (Cth), Schedule 2
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 dependant.
STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 27 November 2023 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 Tonga. She applied for the visa on 17 September 2023. The delegate refused to grant the visa on the basis that her claims lacked substantiating details such as dates and locations, and that no further evidence had been provided despite reasonable opportunities to provide further material.
The applicant appeared before the Tribunal on 27 May 2024 to give evidence and present arguments. The Tribunal hearing was conducted with the assistance of an interpreter in the Tonga and English languages.
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 first issue in this case is whether the applicant has a well founded fear of persecution for a refugee nexus reason or the Tribunal has substantial grounds for believing that, as a necessary and foreseeable consequence of being removed from Australia to Tonga, there is a real risk that she will suffer significant harm. If the Tribunal decides either question in the affirmative then the next issue will be whether any of the exclusions apply. For the following reasons, the Tribunal has concluded that the matter should be remitted for reconsideration.
Religious claims
The applicant’s claims in her protection visa application were accurately summarised in the delegate’s decision in the following terms:
·The applicant left Tonga to work within the PALM Scheme in Australia.
·The applicant converted from Islam to Christianity which is illegal in their region in Tonga and the applicant cannot freely practice their faith in Tonga.
·The applicant experienced harm in Tonga from their local community by being threatened to be reported to Islamic authorities and were cast out of their community.
·The applicant did not seek help within Tonga and do not think they can be protected because there is no way the authorities or Government Departments can help them.
·If the applicant returns to Tonga they will experience mistreatment by way of threats of being reported to Islamic authorities and being cast out of their community.
·The applicant did not try to move to another part of Tonga and does not think they can relocate to another area in Tonga as there is nowhere to go.
The applicant’s claims before the Tribunal were more nuanced. In her oral evidence she described her childhood in the [named] region of Tonga as the youngest of [number] children. Her oldest sibling is around [number] years older than her. She said that as the youngest child she had to ‘do everything at home’ because the older children could earn for themselves and bullied her.
Her parents were both Muslim when she was born. The applicant vaguely recalls her mother covered up and thinks she wore a hijab when the applicant was a young child. The applicant said that her father died when she was [age] years old and her mother became a Morman shortly thereafter, and everything changed. She was raised in the Morman faith after that, she attended a middle school run by the Church of Jesus Chris of Latter-Day Saints and a senior school run by the Free Wesleyan Church. The applicant remains a Morman now and has worked as a missionary. Her siblings are also Mormans but none are missionaries.
The applicant says that Mormans are made fun of in Tonga and assaults can happen, although she has not personally been assaulted and does not think her siblings have been. Her evidence about being cast out of her community is vague, and at best appears to relate to something that occurred when she was seven years old. She has subsequently been educated at a Latter-Day Saints school with a substantially Morman community.
The applicant said that it was illegal to stop being Islamic, even though Tonga is not a Muslim country. She recalls the family being threatened and frightened when they converted to the Morman faith because they had broken Islamic law. Again, this appears to be something that happened a long time ago, and there is no evidence that her siblings in Tonga have been persecuted as a result of their departure from the Islamic faith; indeed the applicant indicated that most of her family had converted without incident.
The Tribunal notes the limited country information available about either conversion from Islam or the Mormon faith generally in Tonga. The applicant’s evidence is that she has not been personally harmed as a result of her work as a missionary and that her brothers and sisters all continue to live in Tonga. The Tribunal is unable to be satisfied on the limited available material that there is a real chance of serious harm to the applicant because of her conversion from Islam or her conversion to the Mormon faith.
The applicant raised economic claims during the Tribunal hearing. She said that the 2022 tsunami had destroyed her home in Tonga and she would not be able to get work. The applicant’s economic claims are vague and affect the population generally. No other refugee nexus reason is pressed or clearly arises from the evidence before the Tribunal.
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).
Family violence claims
The Tribunal considers that a claim for complementary protection clearly arises from the applicant’s evidence about her family during the hearing.[1] During that evidence the applicant displayed considerable distress at the prospect of having to return to live with her family if she returned to Tonga and said that her brothers had hit her in the past. The Tribunal asked how frequently this had happened and the applicant said that ‘it always happens’.
[1]
On further enquiry from the Tribunal the applicant said that it was normal in Tonga for men to hit women relatives, and that nothing can be done to stop them. She said that she had once tried to contact the police and her siblings threatened her with violence and homelessness. The applicant was extremely distressed recalling this event. She said that her siblings threatened to throw her out of the house, and that her mother was elderly and unable to stop them from doing so.
The applicant said that her husband has also been assaulted by her brothers and was unable to protect her from them. She said that when they were first married in Tonga they had lived with her family because her husband is from another island. Her sisters came home one evening and found the food unprepared and the house untidy. They attacked her, and her husband intervened to help. Her brothers assaulted her husband. They hit him hard across his back and on his head. He tried to defend himself and failed but a neighbour intervened and broke up the fight. The applicant said that this had all happened before she left Tonga.
Country information
Country information available to the Tribunal indicates that gender-based violence is a significant problem in Tonga.[2] A 2009 national survey found that 68 per cent of women have experienced physical violence by a person other than their partner since the age of 15.[3] The main perpetrators of this violence were fathers and male teachers, and it is speculated that this is due to cultural norms surrounding violence as an accepted form of discipline.[4] The Tribunal accepts that in the applicant’s family the disciplinary role appears to have been taken by her brothers after the death of her father.
[2] 'Freedom in the World 2023 - Tonga', Freedom House, 2023, 20230804131445; 'Country Reports on Human Rights Practices for 2022 - Tonga', US Department of State, 20 March 2023, 20230322104437; 'EU Annual Report on Human Rights and Democracy 2021 Country Updates', European Union, 19 April 2022, p.251, 20220421091254
[3] ‘National study on domestic violence against w omen in Tonga 2009’, Ma’a Fafine mo e Famili Inc, June 2012, p.61, 20230424141907
[4] 158 ‘Pacific partnership to end Violence against Women and Girls (Pacific Partnership) Tonga Country Summary’,
It is relevant that inequitable gender norms appear common in Tonga. According to the 2009 national survey, 83 per cent of women agreed that a good wife obeys her husband even when she disagrees, 64 agreed that a man should show he is the boss and 59 per cent agreed that a wife is obliged to have sex with her husband.[5] Some young girls are compelled by their parents to marry men who have raped them to prevent family shame.[6]
[5] ‘National study on domestic violence against w omen in Tonga 2009’, Ma’a Fafine mo e Famili Inc, June 2012, p.68, 20230424141907
[6] 'Country Reports on Human Rights Practices for 2022 - Tonga', US Department of State, 20 March 2023, 20230322104437
Investigations into domestic violence are predominantly focussed on spousal violence, and statistics about adult sibling violence are difficult to obtain. The statistics about spousal violence are dire. A national survey conducted in 2009 (published in 2012) found that 40 per cent of women who have ever had a partner have experienced physical and/or sexual violence from a partner at least once in their lifetime.[7] In 2022, the deputy police commissioner reported that domestic violence cases were increasing.[8] Underreporting is believed to be high, and it is speculated that most cases are not reported to the police and general awareness of the issue being low.[9] The number of domestic violence cases reportedly increased significantly during COVID-19 pandemic lockdown measures and following the eruption of the Hunga-Tonga-Hunga-Ha'apai volcano January 2022.[10]
[7] ‘National study on domestic violence against w omen in Tonga 2009’, Ma’a Fafine mo e Famili Inc, June 2012, p.40, 20230424141907; ‘Pacific partnership to end Violence against Women and Girls (Pacific Partnership) Tonga Country Summary’, United Nations Women et al, June 2022, p.4, 20230424142623
[8] ‘Country Reports on Human Rights Practices for 2022 - Tonga', US Department of State, 20 March 2023
[9] ‘Domestic violence on the rise in Tonga’, Radio New Zealand, 3 August 2020, 20230424142754; ‘Pacific partnership to end Violence against Women and Girls (Pacific Partnership) Tonga Country Summary’, United Nations Women et al, June 2022, p.4, 20230424142623
[10] ‘Domestic violence cases rise in wake of Hunga Tonga-Hunga Ha'apai eruption, as women call for a power shift in humanitarian response’, ABC News, 17 April 2022, 20230424142938; ‘Domestic violence on the rise in Tonga’, Radio New Zealand, 3 August 2020, 20230424142754; ‘EU Annual Report on Human Rights and Democracy 2021 Country Updates', European Union, 19 April 2022, p.251, 20220421091254; 'Country Reports on Human Rights Practices for 2022 - Tonga', US Department of State, 20 March 2023, 20230322104437
Domestic violence is a criminal offence in Tonga, however it appears from media reports that prosecution rates are low.[11] This may be in part due to the ‘no drop’ policy for domestic violence complaints; once filed, domestic violence cases cannot be withdrawn and must proceed to prosecution in the Magistrate’s Court. That is consistent with the applicant’s report that her siblings made serious threats against her to prevent her making an official report. A national report indicates that many victims of domestic violence do not seek help from the authorities to avoid bringing a bad name to their family, and further that abuse is considered normal or not serious.[12] That is consistent with the applicant’s evidence, and her reasons for not raising domestic violence as a reason for seeking protection until she had lived in Australia for a significant period of time.
[11] ‘Domestic violence on the rise in Tonga’, Radio New Zealand, 3 August 2020, 20230424142754
[12] 173 National study on domestic violence against women in Tonga 2009’, Ma’a Fafine mo e Famili Inc, June 2012, p.99, 20230424141907
It also appears that around 85 per cent of women who experience domestic violence are likely to return to the same environment in which the attack occurred.[13] That is consistent with the applicant’s indication that she will return to the family home out of economic necessity if she returns to Tonga.
Significant harm
[13] 174
The Tribunal is satisfied that there are substantial grounds to believe that the applicant will be at real risk of physical violence from her brothers if she returns to Tonga, and that neither her husband nor the authorities can provide her with sufficient protection to reduce the risk to something less than a real risk.
An applicant will suffer significant harm if they will be subjected to torture: s 36(2A)(c). Torture is exhaustively defined in s 5(1) of the Act as an act or omission by which severe pain or suffering, whether physical or mental, is inflicted on a person. The pain or suffering must be intentionally inflicted, in the sense that there is an actual, subjective intention on the part of a person to bring about the suffering by their conduct.[14] Furthermore, it must be inflicted for one of five purposes: for the purpose of obtaining from the person or a third person information or a confession; for the purpose of punishing the person for an act which they or a third person committed or is suspected of having committed; for the purpose of intimidating or coercing the person or a third person; for any purpose related to one of those purposes; or for any reason based on discrimination that is inconsistent with the Articles of the International Covenant on Civil and Political Rights (the ICCPR).
[14] SZTAL v MIBP; SZTGM v MIBP (2017) 262 CLR 362 at [26]–[27] and [114]
The Tribunal accepts the applicant’s evidence that her brothers and sisters use physical violence to intimidate and coerce her to perform household duties that are based in the discriminatory allocation of household roles to women and youngest children. The Tribunal finds that it amounts to torture for the purpose of s36(2A)(c).
The economic situation post-tsunami in Tonga has been reportedly severe. The Tribunal accepts the applicant’s evidence that she would be financially dependent on her family if she returned to Tonga and accepts the country information to the effect that victims of domestic abuse return to the family home in which they suffered the abuse, not as a matter of election but as a matter of compulsion. The Tribunal finds that exposure to domestic violence amounting to torture is a necessary and foreseeable consequence of her return to Tonga and that relocation to another part of the country is not reasonable in the circumstances.
The Tribunal is persuaded on the country information that the applicant could not obtain protection from an authority that reduced the risk of harm to something less than a real risk. There is no evidence that the applicant has a right to reside in any third country.
The Tribunal is satisfied that the applicant is a person in respect of whom Australia has protection obligations under s 36(2)(aa).
DECISION
The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(aa) of the Migration Act.
Jessica Henderson
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.
…

United Nations Women et al, June 2022, p.4, 20230424142623

‘Domestic Violence In Tonga: The WCCC’s Efforts’, Borgen Project, 23 December 2020, 20230904102639

[2024] AATA 3367

4 July 2024

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Statutory Construction

Jurisdiction

Natural Justice