2405700 (Refugee)

2405700 (Refugee) [2024] AATA 2496 (11 June 2024)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICATION FOR REVIEW:                 Application for review of a decision made by a delegate of the Minister for Home Affairs to refuse to grant the applicant a Protection XA subclass 866 Visa under s 65 of the Migration Act 1958 (Cth) (‘the Act’)
APPLICANT’S REPRESENTATIVE:        Unrepresented
CASE NUMBER:  2405700
COUNTRY OF REFERENCE:                  Solomon Islands
MEMBER:Kate Chapple
DATE:11 June 2024
PLACE OF DECISION:  Brisbane
DECISION:The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(a) of the Act.

Statement made on 11 June 2024 at 8:51am
CATCHWORDS
REFUGEE – protection visa – Solomon Islands – membership of particular social group – long-term victim of partner violence – coercive control and physical, emotional and verbal abuse from former boyfriend – boyfriend’s other anti-social and violent behaviour and association with police – previously employed in same workplace and likely to continue working in same sector – familial and social connections and motivation to trace applicant – consistent and credible evidence and supporting statements – country information – prevalence of gender-based violence, limited police response and traditional cultural attitudes – decision under review remitted
LEGISLATION
Migration Act 1958 (Cth), ss 5AAA(2), 5H(1)(a), 5J(1), 36(2)(a), 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 dependants.
EVIDENCE BEFORE THE TRIBUNAL
Protection visa application

Protection visa application lodged 8 November 2023 setting out the following claims (spelling and grammatical errors not corrected):
1.1.[reason applicant left Solomon Islands] I left Solomon Islands for security reasons and for my personal safety.
1.2.[harm experienced by applicant in Solomon Islands] I suffered a lot of physical harassment, emotional abuse and verbal abuse from my ex-boyfriend [Mr A]. I experience a lot of harassment especially at work due to him being drunk and jealous and that was when I cope all the abuse.
1.3.[help sought by applicant in Solomon Islands] I did not try and seek help as I was engaged to him and I hope he would change as he was also [an occupation 1]. That never happened. My ex was full of jealousy, and it make my life sad and hard as I deal with people every day. I was never allowed to talk to another man even if it was for work purposes. Culturally, when I am engaged to marry [Mr A], he starts being the boss and I have to follow all his wishes whether I like it or not.
1.4.[reason applicant didn’t relocate to another part of Solomon Islands] I did not move to another part of Solomon Islands as Solomon Islands is a very small country and there is no way I can hide from [Mr A]. He will surely hunt me done and find me. Secondly, land in Solomon Islands is owned by tribal groups and I do not have the right to relocate to other parts of Solomon Islands. I only have rights to live where my parents have rights to.
1.5.[what applicant thinks will happen if she returns to Solomon Islands] Currently, [Mr A] is looking for ways to get to me here in Australia, but it is expensive to get here and I do not think he will afford to get here. Therefore, if I return to Solomon Islands, I will surely be going back into the same old routine of jealousy, harassment, emotional and physical abuse from [Mr A].
1.6.[reason applicant thinks she’ll be harmed or mistreated if she returns to Solomon Islands] As stated in previous questions, I will be harassed, abused and harm by my ex-[Mr A]. I always run back to my parents but then I had to be returned to [Mr A] as we were engaged to be married. There were days I went without food as I was too stressed about what he will do to me next as he was (still is) always on the booze.
1.7.[reason applicant thinks Solomon Islands authorities won’t protect her] I do not think any authority in my country will protect me. My situation will be seen as a domestic issue that can be resolved at the family and church level.
1.8.[reason applicant can’t relocate within Solomon Islands] I cannot relocate as I do not have rights to move to other parts of Solomon Islands. Land in Solomon Islands is owned by tribal groups thus, relocating to other parts is not an option.
Statement by applicant submitted to the Department under cover of email dated 15 January 2024.
Decision record dated 29 February 2024 relating to the delegate’s refusal decision.
Departmental case file relating to the applicant.
Application for review
Application for review lodged 21 March 2024.
The Tribunal wrote to the applicant inviting her to attend a hearing on 4 June 2024 and to provide pre-hearing submissions.
Prior to the hearing, the applicant provided to the Tribunal:
7.1.Confirmation that the applicant intended to participate in the hearing.
7.2.Letter from applicant’s first cousin dated 10 March 2024.
7.3.Letter from schoolteacher dated 15 March 2024.
7.4.Letter from applicant’s mother dated 17 March 2024.
7.5.Letter from [occupation 1] at [Employer 1] dated 19 April 2024.
7.6.Letter from [occupation 1] at [Employer 1] dated 23 April 2024.
The Hearing
The applicant appeared before the Tribunal at a hearing conducted in person on 4 June 2024, with the assistance of an interpreter (in person) in the Pidgin Solomon Islands and English languages. The applicant was unrepresented.
The applicant gave evidence, summarised by the Tribunal as follows:
9.1.The applicant was born in [Year] in Honiara where she grew up with her parents and two [brothers]. Her father, now aged [Age], used to work for the [employer 2], and is no longer working. Her mother, now aged [Age], is [an occupation 2] at [Employer 3]. The elder of her brothers, now aged [Age], works for a [firm], and her other brother, now aged [Age], isn’t working. The parents and brothers continue to live together in the family home in [location], Honiara. The applicant was brought up in a Christian home, she had a very good life, her parents taught her well and were able to provide everything she needed. She has a good relationship with her parents and brothers.
9.2.The applicant was educated in Solomon Islands. With her parents’ support, she studied [Subject 1] from 2009 to 2011. After graduating, she worked at [Employer 1] in Honiara from 2012 to 2023, progressing from [job title 1] to [job title 2].
9.3.From 2012, the applicant’s parents lived in [Country] for nine years so her mother could complete her Masters studies. Her brothers lived with the parents in [Country] and completed their secondary school and university studies there. As the applicant had begun her [occupation 1] work, she remained in Honiara, and continued living in the family home with her grandfather.
9.4.The applicant met her now former (named) boyfriend in 2006 when she was in year [Number] at school. They were in the same youth group at the [Church] in [Location]. Their families knew each other; both sets of parents were from [named] province, and they lived only doors away from one another. The applicant clarified the boyfriend’s name as he is referred to differently in some of the submitted material.
9.5.The applicant’s relationship with the boyfriend began in 2006. They were engaged in 2008, however they never made plans to marry because in 2009 they were both studying [Subject 1] in different places, and in 2010 they started experiencing problems. Rather than the relationship ending, it continued on and off whilst the applicant remained in Solomon Islands. She only considered the relationship over when she left the country and came to Australia in August 2023.
9.6.In February 2010, the applicant and boyfriend attended [an event] in Honiara together. She noticed that his behaviour had started to change, she learned that he was involved with another girl, and she found in his backpack letters from other girls. In second semester 2010, the boyfriend was suspended from university for a year for throwing a glass and breaking a table in the dining hall. During his suspension, he returned to live with his parents at home in Honiara. The boyfriend became secretive, not taking calls in front of the applicant; and when the applicant didn’t give him what he wanted, he quickly became aggressive and accused her of not helping him. His sister also told her about his propensity for aggressive behaviour. The applicant didn’t feel she could tell her parents what was happening.
9.7.In 2011, the applicant was at a soccer match with the boyfriend. A girl was at the match who the boyfriend had been with, and she was calling out to them. He kicked the girl in the stomach then produced a knife; the applicant tried to block him, but the boyfriend beat the girl.
9.8.The boyfriend returned to university in second semester 2011, however a year later he was suspended again for a year, so returned to live with his parents at home in Honiara from second semester 2012. The applicant had begun her [occupation 1] work by then, however he had not completed his studies, so just stayed at home. Because they were engaged, the applicant and the boyfriend would stay together for periods of time either at his parents’ home or her parents’ home.
9.9.During this time, the applicant observed that the boyfriend’s behaviour worsened towards her: he accused her of showing off to other men; he gave her permission to talk to some men and not others; he demanded money from her; he was constantly checking that she was at the [workplace] working; sometimes he would come to the [workplace] drunk and harass her when she was with [specified people]; if she didn’t answer his calls he accused her of going out with other men and at times would arrive at the [workplace] and demand that she come out of the building or he would drag her out by her hair or [clothes]; she couldn’t risk associating with male staff or students at the [workplace] for fear that he would confront her. Other [occupation 1s] saw what he was doing and tried to stop him; the [workplace] itself did nothing.
9.10.The boyfriend returned to university in second semester 2013 and came back to Honiara for holidays in November 2014. Initially, relations between the two were okay. The applicant had paid for the boyfriend to go to Australia late December to record a video of his church [group], and for them both to attend a church-run pre-camp in [Town 2] and a [Church group] camp in [City] in early to mid-January 2015. On one occasion during this time, when they were in Brisbane together, he got angry because she told him she couldn’t afford to buy him a pair of shoes, and he left her stranded and scared in a city she didn’t know.
9.11.On an occasion back in Solomon Islands, the boyfriend left the applicant stranded at night in a dangerous area when he demanded money and she refused. On many occasions he got angry with her for catching a cab, accusing her of having an affair with the cab driver.
9.12.The applicant and the boyfriend also travelled to Australia in 2018 for Solomon Island independence celebrations.
9.13.The boyfriend completed his [Subject 1] studies in 2019. After graduating, he got a job at [Employer 1]. He had his own money then and his behaviour got much worse. He did what he wanted and bought his own alcohol. The applicant never knew where he was; her cousins told her he was out with other women. One evening in September 2019 her [brother] went to a club with his cousins, and they confronted the boyfriend about his behaviour. They told him he shouldn’t be with other women because he was already in a relationship with the applicant, it was culturally not right, and should have to pay. The boyfriend told the applicant about the incident, and that he threatened the brother and cousins that “one fine day” they’ll have to watch out for him.
9.14.In 2019, when COVID started, the applicant was in quarantine as she was a frontline worker. The boyfriend didn’t want her to do frontline work, however she insisted because she didn’t want to see him.
9.15.On other occasions in 2019, the boyfriend called the applicant in the early hours of the morning while he was having sex with other women, and at the same time accused her of being with other men. He was messing with her head.
9.16.Sometime in 2019, the applicant approached police about the boyfriend’s behaviour. The police station was close to their home. They asked her his name and nothing more. They said she didn’t have any physical injuries, so she needed to go home and sort it out. She expected to get a call from the police asking more questions, however she heard nothing further.
9.17.On another occasion in October 2020, the applicant had been selling food at the markets on a Sunday. The applicant had run out of phone credit so couldn’t call the boyfriend. Her plan was to catch a bus to a shop, buy phone credit and call him. The boyfriend accused her of catching a cab, of lying, of being with other men. When she got home, they argued, and he yanked her hair. The cousins and other family member witnessed the altercation and got into a fight with him about how he was treating her. They demanded he pay $2000 compensation. The boyfriend forced the applicant to pay him $700 because she had caused the situation. The applicant’s father ruled that compensation would not be paid because the cousins would only spend the money on alcohol, and it would tarnish their name. The boyfriend however returned only $400 to the applicant and spent the remainder on alcohol.
9.18.In 2020, the boyfriend came to the applicant’s parents’ home with cuts on his knuckles asking for a tetanus shot. He told her he’d hit another man when they were drinking. She told him he needed to be careful, or the police would get involved. He got angry and accused her of taking sides with the man he’d hit; and told her he wasn’t worried because he had a good relationship with the police, they drank together.
9.19.On one occasion when the boyfriend had not met a commitment to sing at the church because he had gone on a camp with another woman, the applicant’s brother confronted him and told him to stop going crazy with other women. The boyfriend grabbed a knife to stab the brother, but stopped because it was in full view of onlookers. They later reconciled.
9.20.Everyone in the family saw what was happening, but maybe because of their close relationship with the boyfriend, they probably decided it was best not to intervene. Family members told the applicant to get away from him. She had to look for a way out; it wasn’t going to be enough to move to another [occupation 1 workplace] because he would find her.
9.21.The boyfriend had done so many things to her that affected her emotionally, and he was disturbing her work at the [workplace], however she didn’t want to involve her cousins because she was worried they would get into a fight with him and end up in jail. She decided she would come to Australia. She told her boss, parents and friends that she was going on a holiday and would do some study, then would return at a later date sometime. They kept her departure a secret from the boyfriend. She came to Australia in August 2023.
9.22.Once the applicant had arrived in Australia, she finally felt safe. Her last contact with him was about a month before she left Solomon Islands. The boyfriend tried to add her on [Social media], but she kept blocking him. The boyfriend found out she was in Australia when her cousins here loaded photos of a celebration she was part of. The applicant posts bible texts and church programs on her [Social media].
9.23.The applicant keeps in touch with family and friends through [Social media] and [messenging app]. They tell her the boyfriend is not happy and is looking for a way to come to Australia. She’s not sure of his reason, but he’s asked them how he could arrange to come here. She doesn’t know whether the boyfriend is in another relationship; he had multiple affairs when they were together. He is still working at [Employer 1] and lives at his older sister’s home.
9.24.While in Australia, the applicant has completed a TAFE English course. After she applied for a protection visa, she started a Cert III in [Subject 2], which she has since completed. She has an offer to work at a [workplace 2] in [work sector].
9.25.Knowing her circumstances, an older woman in [Town 3] advised the applicant to apply for a protection visa; she helped her with the application. The applicant is scared of the boyfriend; she doesn’t know what he would do to her if she returned to Solomon Islands. He has already done so many things to her, which may seem small, but now that she has gone away, to return, it could become bigger and more serious.
9.26.If the applicant returned to Solomon Islands, she could only live with her parents. She’s not sure whether she would get a job at the [workplace] because she left without resigning. She has been in contact with the [workplace]; they understand why she left.
9.27.The boyfriend has not ever physically beaten the applicant, only dragged her and pulled her hair. She thinks it’s because they live in an area where there are many people. She has always tried to say little so as not to inflame him. She doesn’t know what he would do to her if they were away from other people. She wants to find any way that she can be kept away from him.
Country information
Gender-based violence is prevalent in the Solomon Islands. Two thirds of women aged 15 to 49 report having experienced physical or sexual abuse by a partner.[1] Sexual harassment is also a widespread problem.[2] Gender based violence is widely unreported.[3] Key reasons for failing to report abuse include pressure from male relatives, fear of reprisals, feelings of shame and cultural taboos of discussing such issues.[4] Inequitable gender norms are common in the Solomon Islands. Three-quarters of men and women believe violence is acceptable, especially if a woman is ‘disobedient.’[5]
[1] ‘Solomon Islands is no paradise for women. These people are leading the charge for change’, ABC News, 6 April 2020.
[2] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8
[3] 'Freedom in the World 2022 - Solomon Islands', Freedom House, 28 September 2022
[4] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7
[5] ‘Solomon Islands is no paradise for w omen. These people are leading the charge for change’, ABC News, 6 April 2020
Domestic violence is a criminal offence punishable by up to three years in prison and a substantial fine.[6] The law criminalises rape, including spousal rape, with a maximum penalty of life imprisonment.[7] Sexual harassment is not illegal.[8]
[6] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7
[7] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7
[8] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8
Very few domestic violence cases are prosecuted in the Solomon Islands.[9] Of the cases that are reported to the police, in most instances victims dropped charges before a court appearance or settled cases out of court.[10] Prosecutions are rare due to low judicial and police capacity and cultural bias against women.[11] A 2019 joint study by Australian Aid and the Government of the Solomon Islands examined how police respond when women report family violence incidents. In most cases (47 per cent) women reported receiving no information or action from the police, were told to ‘come back later’ or discouraged from filing a report.[12] When domestic violence reports are filed with the police, it can take up to two years for the charges to be heard in court.[13]
[9] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7
[10] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7, 20230322103040; 'Freedom in the World 2022 - Solomon Islands', Freedom House, 28 September 2022
[11] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.7
[12] ‘Women’s experiences of family violence in Solomon Islands’, Australian Aid & Government of the Solomon Islands, 26 November 2019, p.26 & p.6
[13] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8.

The law in the Solomon Islands provides for access to medical services, counselling, legal support and a safe place within the community for survivors of domestic violence if they cannot return home.[14] The government runs a referral system to coordinate these services; however, referral agencies often lack funding, especially in rural areas.[15] During 2022, NGOs operated 11 safe houses throughout the country.[16]
[14] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8.
[15] 'Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8
[16] ‘Country Reports on Human Rights Practices for 2022 - Solomon Islands', US Department of State, 20 March 2023, p.8.
Domestic and family violence – dynamics and risk factors
Section 3.2 (Understanding coercive control) of the National Domestic and Family Violence Bench Book 2023 states that:
Coercive control is almost always an underpinning dynamic of family and domestic violence: Perpetrators exert power and dominance of victim-survivors using patterns of abusive behaviour over time that create fear and deny victim-survivors liberty and autonomy.
There is no single agreed definition of coercive control. However, research consistently identifies that the behaviours and tactics associated with coercive control can be subtle, difficult to identify and different in each relationship. Coercive control manifests and is experienced in various ways in different class and cultural contexts. The impacts of coercive control are pervasive, and can be physical, emotional, psychological, spiritual, cultural, social and financial. Impacts are also intersecting and cumulative, rather than incident-specific. Victim-survivors commonly describe coercive control as feeling like ‘walking on eggshells’ and report they need to ask permission to do small everyday things and fear the repercussions of not fulfilling their abuser’s expectations or demands.
Use of retaliatory violence or self-defence against a perpetrator are not coercive control.
Coercive control is mainly perpetrated by men against women. Perpetrators can exert power and dominance over victim-survivors in current and former intimate partner relationships. Coercive control can also be perpetrated in broader family relationships, such as against children or young people by parents or relatives, against parents or elders by adult children or grandchildren, or between siblings. Coercive control is particularly prevalent in relationships where there is an imbalance of power. Professor Evan Stark has described coercive control as “a pattern of domination that includes tactics to isolate, degrade, exploit and control” victims.
The behaviours associated with coercive control can take many different forms including any of the forms of domestic and family violence considered in this benchbook. Common behaviours that may be used by perpetrators as part of coercive control include but are not limited to:
·     emotional manipulation including humiliation and threats,
·     surveillance and monitoring, often carried out online,
·     isolation from friends and family,
·     rigid rules about where the person can eat, sleep or pray,
·     placing limits on economic autonomy.
As coercive control depends on context, evidence or information about the context may assist the decision-maker to identify coercive control and help ensure the victim-survivor is not misidentified as a perpetrator.
In situations involving coercive control the abuser draws on their specific knowledge of the victim to entrap the victim, and the tactics used to assert control may change over time:
·     The abuser may target the victim’s children to extend their control over the victim, sometimes using children as a tool of surveillance or intimidation.
·     The abuser’s attack on the victim’s autonomy can involve utilising systems, including the legal system (sometimes referred to as ‘systems abuse’).
Research has identified that domestic and family violence is rarely a single incident, rather it is a pattern of behaviour that may or may not include physical force, and extends beyond the home and beyond the duration of a relationship. These patterns of behaviour may occur throughout a relationship, or may be initiated or exacerbated at times of heightened risk, for example, pregnancy, attempted or actual separation, and during court proceedings.
In some relationships physical violence is part of the pattern of coercive control but incidents of physical violence may be routine, minor and frequently repeated. Other victims-survivors report that physical violence is rare or a once off or occurred early in the relationship, but establishes the abuser’s capacity and potential for physical violence. Some people who experience coercive control do not experience physical violence.
Coercive control can be damaging even when there is no physical violence. Many victim-survivors identify that non-physical abuse deeply impacts on their sense of self and freedom, and often continues to affect them years after separation. Many victim-survivors of domestic and family violence report that the most difficult forms of abuse they experienced were non-physical forms of abuse, especially emotional abuse.
The community and broader service and response system, including law enforcement and the courts, can typically focus on physical violence and single or episodic acts of violence in isolation, rather than considering patterns of physical and non-physical behaviour over time and their cumulative impacts. This can make it easy for perpetrators to hide their actions from systems and can lead to a perpetrator’s subtle and highly contextualised abuse, and the compounding impact of coercive control, being overlooked and/or minimised. Incident-based responses can also heighten the risks of misidentifying the victim-survivor as the perpetrator.
Researchers have suggested that coercive control is a common thread running through risk identification and assessment for domestic violence.
In NSW, a detailed analysis of intimate partner homicides between 2008-2016 demonstrated that 99% (111/112) of the homicides were preceded by coercive control. The Queensland Domestic and Family Violence Review and Advisory Board in its 2018-19 Annual Report reported evidence of controlling behaviours by 39.4 per cent and obsessive and/or jealous behaviours by 37.8 per cent of family and domestic violence homicide offenders between 2006 and 2018.
Section 4.2 (Factors affecting risk) of the National Domestic and Family Violence Bench Book 2023 states that:
The following factors are commonly identified in academic literature, domestic violence death reviews and a range of risk assessment tools as key signifiers of risk for the escalation of domestic and family violence. It is not an exhaustive list and other resources may include additional factors. The distinguishing characteristic of domestic and family violence is that it can present in many forms and can occur within a variety of relationships and is most likely to involve a complex pattern of controlling behaviour and violence over a period of time, rather than a single incident. This is often referred to as coercive control. One study has described coercive control as the ‘golden thread’ running through risk identification and assessment for domestic violence. It is likely therefore that risk will heighten where a perpetrator increasingly engages in multiple forms of violence or abuse, or does so more frequently, intensely or severely. Judicial recognition of this is critical to understanding the ongoing and ever-changing risks of domestic and family violence unique to the circumstances of each case before the court, and the need to regularly reassess risk throughout the course of judicial proceedings.
…
Victim fear
According to an evaluation of risk assessment tools carried out in NSW the victim’s self-perception of risk of future intimate partner violence is one of the strongest predictors of future intimate partner violence. A victim’s intuitive sense of being in danger has been identified as a key lethality indicator present in 53.2 per cent of intimate partner violence related homicides recorded in Queensland between 2011 and 2018. It is vital that victims are believed, regardless of how agencies assess their presentation. The Queensland Death Review and Advisory Board observed that agencies had assessed risk with a focus on the victims’ presentation rather than victims’ expressed concerns for their safety, and resulted in failures to refer victims to High-Risk teams for support. The Queensland Death Review and Advisory Board further observed that victims who do not fit agency understandings of the “ideal victim” may not have their fears taken seriously if they present as ‘jovial’ or ‘happy’, resulting in miscalculation of actual level of risk or potential future harm. Regardless of presentation, victim fear and help-seeking behaviours were the highest level lethality indicator observed across the period examined in the Queensland Death Review and Advisory Board Annual Report 2021-22.
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Coercive and controlling, jealous, obsessive behaviours by the perpetrator
Findings from the New South Wales Domestic Violence Death Review Team’s 2019-2021 Report indicate a strong correlation between accounts of coercive control in relationships prior to homicide; of male homicide perpetrators identified as the predominant abuser:
·   96.7 per cent used emotional and/or psychological abuse against the female predominant victim before the homicide, including verbal denigration, threats regarding child custody, victim-blaming, gaslighting, exploiting a victim’s mental illness, unfounded allegations of infidelity and threats of self-harm or suicide to control a victim.
·   15.1 per cent had an identifiable history of sexual abuse (this figure is suspected to not reflect the true prevalence of sexual abuse in these relationships);
·   59.2 per cent used social violence against the female predominant victim, including controlling the victim’s contact with family and friends, abuse, threats or rudeness to the victim’s friends or family, intentional relocation away from support networks, friends and family, restricting access to transport, and controlling the victim’s personal appearance;
·   31.4 per cent used economic and/or financial violence against the female predominant victim, including withholding and controlling use of and access to money, scrutinising spending and unrealistic expectations for expenditure on necessities, preventing the victim from working or controlling wages and coerced debt.
·   30.6 per cent stalked the female predominant victim during the relationship and 51.4 per cent did so after the relationship had ended, including physical following, hiring someone to surveil the victim, loitering near or breaking into the victim’s home or work, reading a victim’s diary, using devices to track the victim’s location, persistently messaging a victim’s phone or social media, maintaining surveillance over the victim’s phone, email or other accounts, covertly recording the victim’s activities, and engaging with the victim on social media/dating sites under a false identity.
In addition, 72.7 per cent of male predominant abusers used physical violence against the female predominant victim before her death.
Analysis of the National Death Review Network’s National Minimum Dataset identified the following types of coercive and controlling behaviour exhibited by male primary domestic violence abusers who killed female domestic violence victims in its 2022 report:
·   81.6 per cent emotionally and/or psychologically abused their victim;
·   63.2 per cent socially abused their victim;
·   41.5 per cent stalked their victim;
·   27.4 per cent financially abused their victim;
·   16 per cent were identified as having sexually abused their victim (this is recognised as likely an undercount of the true incidence of sexual violence).
This was in addition to the 79.7 who used physical violence against their victim.
A recent study which interviewed loved ones of female intimate partner homicide victims found that coercive control was present in all informant’s narratives of the relationship between the victims and homicide perpetrators. The Victorian Systemic Review of Family Violence Deaths 1 January 2011 to 31 December 2015 found that 78.9 per cent of domestic and family violence homicide victims were identified as having a prior history of domestic and family violence victimisation at the hands of the homicide perpetrator.
The controlling behaviours referred to in the previous paragraphs (sometimes referred to as coercive control) may involve the perpetrator spatially confining or restraining the victim; asserting exclusive possession over the victim; monopolising the victim’s skills and resources; restricting the victim’s access to finances and employment; or preventing the victim from keeping in touch with social networks, escaping the abusive relationship, or seeking help and support. The effect may be to physically and socially isolate the victim, and, over time, undermine the victim’s sense of identity, independence and self worth, and place them at greater risk of further domestic and family violence.
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Misuse of alcohol or drugs by perpetrator
National death review data indicates that problematic substance abuse was a factor in over 60 per cent of homicides where a male offender killed a female victim. A quarter of male homicide offenders engaged in problematic drug and alcohol use in the lead up to or at the time of the homicide, over half engaged in problematic alcohol use at the time of the homicide (27.1 per cent used alcohol and no other drug) and one third engaged in problematic drug use in the lead up to or at the time of the homicide (8.3 per cent engaged in problematic drug use only). The Victorian Systemic Review of Family Violence Deaths 1 January 2011 to 31 December 2015 found that 35.3 per cent of family violence homicide offenders misused substances at the time of the fatal incident.
CONSIDERATION OF CLAIMS AND EVIDENCE
The Tribunal notes that s 5AAA(2) of the Act provides that it is the applicant’s responsibility to specify all particulars of her protection claim and to provide sufficient evidence to establish the claim.
In considering the applicant’s claims and evidence, the Tribunal has taken account of the Department of Home Affairs ‘Refugee Law Guidelines’ and ‘Complementary Protection Guidelines’, the country information and the recognised dynamics and risk factors associated with family and domestic violence set out in this decision record.
The Tribunal has made an assessment of the credibility of the applicant’s claims and evidence having regard to the Migration and Refugee Division Guidelines on the Assessment of Credibility.
The Tribunal considers the applicant’s written claims and oral evidence represent a credible and consistent account of her experiences in Solomon Islands leading to her coming to Australia and to her application for a protection visa, in particular the nature and dynamics of her relationship with the former boyfriend.
The Tribunal notes the authors of the letters from third parties (and listed in paragraph 7 of this decision record) variously appear to identify the applicant’s former boyfriend by one of two surnames. The Tribunal further notes the applicant’s explanation that one name used is the former boyfriend’s middle name, and the other name used is the former boyfriend’s surname.
The Tribunal is satisfied that the authors of the letters are identifying the same individual, being the applicant’s former boyfriend.
The Tribunal notes the letter from the applicant’s mother (dated 17 March 2024) states that the relationship between the applicant and the former boyfriend ended a few years ago. The Tribunal further notes the applicant’s oral and written evidence that the relationship ended in August 2023.
The Tribunal accepts the applicant’s evidence that whilst the relationship had problems since 2010, and they were “on and off” over the years, she did not consider the relationship over until she had left Solomon Islands and was away and safe from the former boyfriend.
The Tribunal considers the letters credible and consistent corroborative evidence of the applicant’s protection claims.
The Tribunal notes:
25.1.The applicant was in an intimate partner relationship with the former boyfriend from the age of [Age] while she was still at school, and the following year they were engaged to be married, however they never progressed their plans to marry. In 2009, both the applicant and the former boyfriend embarked on their [Subject 1] studies at different universities in Solomon Islands.
25.2.The applicant proved herself to be dedicated and disciplined in her studies, graduating in 2011 and commencing her employment as [an occupation 1] with [Employer 1] in Honiara in 2012.
25.3.The former boyfriend, on the other hand, was suspended by his university twice, for a year at a time, due to violent conduct causing property damage, and did not complete his [Subject 1] studies until 2019.
25.4.It was when the former boyfriend returned to Honiara during his suspensions and holidays and following his graduation that the relationship with the applicant increasingly deteriorated over time.
25.5.The former boyfriend’s recurrent conduct towards the applicant from 2010 to 2023 included: being involved with multiple other women, monitoring and controlling the applicant’s engagement with men at the church and at her workplace, allowing her to speak with certain men and not others, presenting at her workplace, physically and roughly removing her from her workplace, accusing her of showing off to and being with other men, accusing her of not helping him, demanding money from her, verbal aggression, exposing the applicant to his intimate relations with other women, abandoning her in situations likely to incite fear in her, aggression, threats and violence towards others including the applicant’s family members, and associated regular misuse of alcohol.
25.6.The former boyfriend has never physically beaten the applicant, only dragged her and pulled her hair.
25.7.The applicant has always tried to say little so as not to inflame the former boyfriend.
25.8.The former boyfriend has asked the applicant’s family about how he can arrange to come to Australia.
25.9.The applicant is scared of the former boyfriend and doesn’t know what he would do to her if she returned to Solomon Islands and if they were away from the view of other people. He has done so many things to her, which may seem small, but if she were to return after having gone away, it could become more serious.
The Tribunal notes the country information reports that:
26.1.Gender-based violence in Solomon Islands is widely unreported, the key reasons being pressure from male relatives, fear of reprisals, feelings of shame and cultural taboos of discussing such issues.
26.2.Very few domestic cases are prosecuted in Solomon Islands, and of the cases that are reported to the police, in most instances victims dropped the charges before a court appearance or settled cases out of court.
26.3.Women reported receiving no information or action from the police, were told to come back later or discouraged from filing a report. When reports are filed with the police, it can take up to two years for the charges to be heard in court.
The Tribunal notes the instruction provided by the National Family and Domestic Violence Bench Book regarding understanding coercive control and the factors affecting risk.
The Tribunal notes in particular that:
28.1.Coercive control manifests and is experienced in various ways in different cases and cultural contexts. The impacts are pervasive, and can be physical, emotional, psychological, spiritual, cultural, social and financial. Impacts are also intersecting and cumulative, rather than incident-specific.
28.2.Victim-survivors report they need to ask permission to do small everyday things and fear the repercussions of not fulfilling their abuser’s expectations or demands.
28.3.Coercive control can be damaging even when there is no physical violence. Many victim-survivors identify that non-physical abuse deeply impacts on their sense of self and freedom, and often continues to affect them years after separation.
28.4.The distinguishing characteristic of domestic and family violence is that it is most likely to involve a complex pattern of controlling behaviour and violence over a period of time and is often referred to as coercive control. It has been described as the golden thread running through risk identification and assessment.
28.5.A victim’s intuitive sense of being in danger has been identified as a key lethality indicator in over 53% of intimate partner violence related homicides recorded in Queensland in 2011 and 2018.
28.6.The New South Wales Death Review 2019-2021 report indicates a strong correlation between accounts of coercive control in relationships prior to homicide.
28.7.Controlling behaviours may involve the perpetrator spatially confining or restraining the victim; asserting exclusive possession over the victim; monopolising the victim’s skills and resources; restricting the victim’s access to finances and employment; or preventing the victim from keeping in touch with social networks, escaping the abusive relationship, or seeking help and support.
28.8.National death review data indicates that problematic substance abuse was a factor in over 60% of homicides where a male offender killed a female victim.

The Tribunal considers the applicant has a genuine fear of serious harm being perpetrated against her by the former boyfriend if she returns to Solomon Islands, and on that basis, the subjective element of ‘well-founded fear’ under the refugee criteria is established.
The Tribunal notes that for a fear of persecution to be well-founded, there must be a factual or objective basis or justification for that fear, and a real or substantial chance of being persecuted as distinct from a remote chance.
The Tribunal considers that the applicant was in a relationship for 13 years in which she was repeatedly the victim of coercive control perpetrated by the former boyfriend.
The Tribunal considers that, whilst the applicant on her own evidence experienced relatively minor physical harm perpetrated by the former boyfriend, it is likely she has been damaged emotionally, psychologically, financially, socially and culturally by the coercive control perpetrated by the former boyfriend.
The Tribunal considers the evidence of the former boyfriend’s aggression towards the applicant and aggression and violence towards others including the applicant’s family members, and associated regular misuse of alcohol, strongly indicates a propensity for future aggression and violence.
Taking into account the applicant’s evidence and the third parties’ written corroborative evidence, and the documented factors affecting risk, the Tribunal considers there is a substantial and not remote chance that the applicant will face serious harm perpetrated against her by the former boyfriend in the reasonably foreseeable future if she returns to Solomon Islands.
The Tribunal considers the applicant’s return to Solomon Islands after having left the country under a year ago to be away and safe from the former boyfriend is likely to heighten the chance of serious harm to the applicant.
The Tribunal notes the applicant tried in the past to seek help from the Solomon Islands police, however they told her she didn’t have any physical injuries and she needed to go home and sort it out.
The Tribunal notes the applicant’s observation that everyone in her family saw what was happening with the former boyfriend, but because of their close relationship with him, they probably decided not to intervene.
The Tribunal notes there were instances where the applicant’s brother or cousins tried to confront the former boyfriend about his behaviour towards the applicant, however their intervention was ineffective, including when the applicant’s father disallowed the compensation payment partly on the basis that it would tarnish the family name.
The Tribunal notes the former boyfriend drinks with the local Solomon Islands police.
The Tribunal considers the applicant’s evidence relating to lack of protection from Solomon Islands police and her family are supported by the country information.
The Tribunal notes the applicant could only live with her parents if she returned to Solomon Island and she is not sure whether she could return to her [occupation 1] job at [Employer 1].
The Tribunal notes the former boyfriend continues to work as [an occupation 1] at [Employer 1] in Honiara.
The Tribunal considers that if the applicant were able to return to her [occupation 1] job at [Employer 1] in order to earn sufficient income to support herself, she would be exposed to a heightened chance of serious harm perpetrated by the former boyfriend.
The Tribunal considers that if the applicant were to attempt to relocate to a different [occupation 1 workplace], it is highly likely the former boyfriend would through his [workplace] connections would discover the applicant’s [occupation 1 workplace] and would be highly motivated to track her down.
The Tribunal considers it is highly likely the former boyfriend through familial, social and cultural connections would discover the applicant’s whereabouts no matter where she was located in Solomon Islands and would be highly motivated to track her down.
The Tribunal notes the applicant and the former boyfriend visited Australia on two occasions, in 2015 and 2018.
In addressing the question as to why the applicant did not apply for a protection visa on one of those earlier occasions, the Tribunal notes that, on those occasions, the applicant was in a relationship in which she was the victim of coercive control perpetrated by the former boyfriend, and she and the former boyfriend were together in Australia. The Tribunal considers that in these circumstances it is highly likely the applicant would have been unable to apply for a protection visa without the former boyfriend’s knowledge, intervention and reprisal.
Application of law
The issue in this case is whether the applicant meets the refugee criterion, and if not, whether she is entitled to complementary protection. Attachment A sets out the applicable law.
48.1.The applicant is a citizen of Solomon Islands and a non-citizen in Australia.
48.2.The applicant is a member of a particular social group being a woman from Solomon Islands who is a long-term victim of domestic and family violence.
48.3.The applicant fears being persecuted in Solomon Islands for the essential and significant reason of her membership of the particular social group.
48.4.There is a real chance that, if the applicant returned to Solomon Islands, she would be persecuted for her membership of the particular social group.
48.5.The persecution would involve serious and targeted harm to the applicant.
48.6.The real chance of persecution relates to all areas of Solomon Islands.
48.7.There are no effective protection measures available to the applicant in Solomon Islands.
48.8.The applicant could not take reasonable steps to modify her behaviour to avoid a real chance of persecution in Solomon Islands as her vulnerability to persecution arises from her past experiences of coercive control perpetrated by the former boyfriend over 13 years while she was living in Solomon Islands.
48.9.The applicant has a well-founded fear of persecution as defined in s 5J of the Act.
48.10.The applicant is outside Solomon Islands, her country of nationality, and, owing to a well-founded fear of persecution, is unable or unwilling to avail herself of the protection of Solomon Islands.
CONCLUSION
The Tribunal is satisfied that the applicant meets the refugee criterion and is therefore a person in respect of whom Australia has protection obligations under s 36(2)(a) of the Act.
DECISION
The Tribunal remits the matter for reconsideration with the direction that the applicant satisfies s 36(2)(a) of the Act.
Kate Chapple
Member

ATTACHMENT A
Summary of applicable law
The criteria for a protection visa are set out in s 36 of the Migration Act 1958 (Cth) 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.
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).
Relevant extracts 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 2496

11 June 2024

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Immigration

Statutory Interpretation

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