2450695 (Migration)
[2025] ARTA 968
•3 March 2025
2450695 (MIGRATION) [2025] ARTA 968 (3 MARCH 2025)
DECISION AND
REASONS FOR DECISION
Respondent: Minister for Immigration and Multicultural Affairs
Tribunal Number: 2450695
Tribunal:Senior Member Denis Dragovic
Place:Melbourne
Date: 3 March 2025
Decision:The Tribunal sets aside the decision under review and remits the application for a Humanitarian Subclass 201 visa for reconsideration in accordance with the order that the applicant meets cl 201.222 of Schedule 2 to the Regulations
Senior Member D. Dragovic
Statement made on 3 March 2025 at 10:45 AM CATCHWORDS
MIGRATION – Refugee and Humanitarian (Class XB) visa – Subclass 201 (In-country Special Humanitarian) – Turkish citizenship – residence in Türkiye – holder of a subclass 449 visa – compelling reasons for special consideration – Taliban government in Afghanistan – Hazara – family business association with Westerners – women’s rights – marriage to an Australian citizen – suitable country – capacity of the Australian community for permanent settlement – decision under review remitted
LEGISLATION
Administrative Review Tribunal (Consequential and Transitional Provisions No.1) Act 2024
Migration Act 1958, ss 35A, 65, 78, 338
Migration Regulations 1994, Schedule 2, cls 201.222, 201.311; r 1.03CASES
Plaintiff M64/2015 v MIBP [2015] HCA 50
Any references appearing in square brackets indicate that information has been omitted from this decision pursuant to an order under section 70 of the Administrative Review Tribunal Act 2024 and replaced with generic information.
STATEMENT OF REASONS
APPLICATION FOR REVIEW
This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 29 November 2022 to refuse to grant the visa applicant a Refugee and Humanitarian (Class XB) Subclass 201 visa under s 65 of the Migration Act 1958 (Cth) (the Act).
The visa applicant applied for the visa on 12 July 2022. The delegate refused to grant the visa on the 29 November 2022 on the basis that the applicant held Turkish citizenship and as such the delegate found that the applicant did not meet the criteria for the visa.
The applicant appealed the decision to the then Administrative Appeals Tribunal on 8 December 2022. The AAT was abolished and replaced by the Administrative Review Tribunal (“the ART”) on 14 October 2024. The Administrative Review Tribunal (Consequential and Transitional Provisions No.1) Act 2024 (Cth) (“the Transitional Act”) provides that review applications which were not finalised before 14 October 2024 are deemed to be applications for review by the ART and are to be continued and determined as such.
The applicant appeared before the Tribunal on 5 February 2025 to give evidence and present arguments. The hearing was conducted as a joint hearing with the applicant’s family being the second case (ART case number 2218050). The applicant’s father who was an applicant in the jointly heard matter provided evidence in this matter as the witness.
The applicant was represented in relation to the review.
Is the application a reviewable decision?
Subclass 201 visas are generally a category of visas that are non-reviewable as the visas are generally for people offshore making applications, whereas the Migration Act 1958 requires that for a decision to be a reviewable decision the application for the visa is made while in the migration zone (s338(2)(b)).
But there is a nuanced set of circumstances that lead to subclass 201 visas being granted while onshore and as such may be reviewable.
The applicant arrived legally to Australia on a subclass 449 visa. This subclass of visa was used to relocate Afghan nationals to Australia.
Legislated Instrument 21/080 states that ‘For paragraph 1402(3B)(b) of Schedule 1 to the Regulations, an applicant for a Refugee and Humanitarian (Class XB) visa is in a class of persons if the applicant is of a kind mentioned in subsection (2) or (3).’
(2) The applicant has been granted a subclass 449 visa due to any of the following:
(a) the deteriorating security situation in Afghanistan (the main 449 visa holder);
(b) being a member of the immediate family of a main 449 visa holder at the time that the main 449 visa holder was granted that visa;
(c) being a member of the family unit of a main 449 visa holder;
(d) being a member of the immediate family of a subclass 449 visa holder referred to in paragraph (b).
(3) The applicant:
(a) is a child born in Australia who is taken to be granted a subclass 449 visa by operation of section 78 of the Act;and
(b) is the child of an applicant mentioned in subsection (2).
Schedule 1 1402(3B)(b) relates to the requirements for a valid application. The applicant was found to be a class of persons that met the requirements for the grant of a subclass 449 visa. The visa was granted [in] November 2021. The applicant entered Australia [in] November 2021.
The applicant was then invited to apply for an onshore subclass 201 visa and did so on 12 July 2022. As such the application was made onshore (despite it being on an ‘Offshore Humanitarian visa application form’). It was confirmed as a valid application by way of correspondence from the Department dated 12 July 2022.
The application was refused by a delegate of the Minister on 29 November 2022 because the delegate found that the applicant did not meet clause 201.222 of Schedule 2 of the Migration Regulations 1994, specifically because the applicant is also a citizen of Türkiye.
As noted, the applicant appealed the decision to the then Administrative Appeals Tribunal on 8 December 2022. Section 338 and s338A of the Migration Act provide for what constitutes a reviewable migration and protection decision respectively.
This decision is a ‘migration’ decision as opposed to a ‘protection’ decision, for which s338A would be the relevant section, as s35A defines which visas are protection visas and class XB subclass 201 visas are not defined as such.
Having reviewed s338, I find that the application meets all of the criteria for a reviewable migration decision including, of note, for this type of visa that it was made while the applicant was in the migration zone (s338(2)(b)).
Issue to be considered
The Minister’s delegate refused the applicant’s visa on the basis of the applicant not meeting the primary criteria of any of the relevant subclass criteria within the overarching XB class, namely 200.222, 201.222, 202.222, 203.222, 204.224 of Schedule 2 to the Migration Regulations 1994, nor any of the secondary criteria for members of the same family unit listed in clauses 200.311, 201.311, 202.311, 203.311 and 204.311.
The primary clauses listed above have common considerations of whether there are ‘compelling reasons for giving special consideration to granting to the applicant a permanent visa having regard to’:
(a) the degree of persecution to which the applicant is subject in the applicant's home country; and
(b) the extent of the applicant's connection with Australia; and
(c) whether or not there is any suitable country available, other than Australia, that can provide for the applicant's settlement and protection from persecution; and
(d) the capacity of the Australian community to provide for the permanent settlement of persons such as the applicant in Australia.
In very brief reasons, the Minister’s delegate found that having Turkish citizenship (in the context of (c)) weighed against the applicant and that the weight of the four criteria combined led to there not being the necessary compelling reasons.
I note that the term ‘compelling’ is not defined but has been considered in another context and is found to be circumstances that must force or drive the decision-maker irresistibly to be satisfied: see Plaintiff M64/2015 v MIBP [2015] HCA 50.
I also note that there is no guidance given on the weighting to be given across the four considerations such as whether one or another should be a primary consideration and others secondary. As such I will provide equal foundational weighting to each.
Evidence and considerations
Background
The applicant and the witness provided at the hearing detailed evidence with regards to their lived experience but noting that the situation in Afghanistan drastically changed on 15 August 2021 when the Taliban took over control, the relevance of their experiences in informing the Tribunal on their future circumstances is minimal. For this reason, I will only provide a brief summary of this period of their life.
The applicant was born in Parwan, Afghanistan, in [specified year] but later moved to Kabul with her parents and siblings. In 2008 the applicant’s father (“the father”) opened a [business].
The father’s business grew with clients including [specified international agencies and embassies] as well as some contracts from the Afghan government.
It was claimed, and I accept, that the father did not merely work on projects within the Australian Embassy. He was the [position title] and as such was well known within the community as having worked in direct partnership with the Australian Government.
At the hearing he described his situation at the time as financially ‘very good’. But, as the security situation changed in Kabul, he had to relocate from one district to another. He described fears for his children, including the applicant, such that he had to have them driven to school and picked up after school and they weren’t allowed out without their mother or father accompanying them.
He said that his fears arose from his company’s experiences including people who had worked for him being attacked and he was attacked. The applicant was assaulted once and narrowly escaped an attack while working in Ghazni province where he learned that the local Taliban were interested in him.
The applicant fears kidnapping (by enemies and criminals) as well as harm arising from the Taliban for reasons of her father being associated with Westerners.
The applicants are of the Hazara minority which is another source of her fears.
Following a security incident, the father sought opportunities to leave Afghanistan, so he went to Türkiye to assess the situation. He ended up going several times and in 2020 purchased [a property] as a part of a government scheme allowing for the granting of citizenship for those who invest a certain amount in Türkiye.
The father returned to Türkiye to obtain the documentation for citizenship and then returned for the final time to Afghanistan three months before the fall of the United States backed Kabul government.
In the immediate aftermath of the fall of Kabul the father took his family to Türkiye, staying there through to November 2021.
[In] November 2021 the family were granted the sc449 visas. They arrived in Australia [in] November 2021.
the degree of persecution to which the applicant is subject in the applicant's home country
‘Home country’ is defined in r.1.03 as:
(a) the country of which the person is a citizen; or
(b) if the person is not usually resident in that country, the country of which the person is usually a resident.
The applicant is a citizen of Türkiye and Afghanistan. As such under part (a) the home country could be identified as either country.
Whereas part (b) refers in the alternative to a residency consideration and despite the ‘or’ connecting the two parts, the nature of (b) as it is constructed suggests that the applicant not usually being resident in Türkiye, the home country is the country in which the person is usually a resident. In the applicant’s case this is Afghanistan as the applicants have lived in Afghanistan for their entire life prior to arriving in Australia.
As such, which ever pathway is taken, whether considering the alternative citizenship of Türkiye but usual residence of Afghanistan or the citizenship of Afghanistan and usual residency in Afghanistan, the home country in this context is Afghanistan.
The applicant’s representative provided submissions which included country information relevant to the applicant’s circumstances.
Most broadly, relevant to all applicants is the treatment of Hazara in Afghanistan. DFAT assesses:
3.5 DFAT assesses that Hazaras in Afghanistan face a high risk of harassment and violence from both the Taliban and ISKP, on the basis of their ethnicity and sectarian affiliation. While the level of mistreatment of Hazaras is currently less widespread than was predicted by some sources upon the fall of Kabul, members of the Hazara community have suffered from ISKP terror attacks and Taliban violence, including hundreds of evictions.[1]
[1] DFAT Thematic Report Afghanistan Political and Security Developments August 2021 to January 2022 (January 2022)
The animosity towards Hazara is not arbitrary but rather systematic, arising from the values and beliefs of the Taliban.[2] In addition, while the Taliban have taken a pragmatic approach, as noted below, other groups such Islamic State in Khorasan Province are explicitly targeting Shia and Hazara throughout Afghanistan.[3]
[2] Ibid [3.8]
[3] Ibid [3.4]
Noting that the DFAT report would have relied on information from late 2021, I turn to more recent reporting by other groups which all report ongoing physical violence and harassment, targeted assassination and official discrimination towards Hazara.[4]
[4] Genocide Watch and Human Rights Watch as representative sources.
Conversely, Hazara hold senior positions in the Taliban government including three deputy ministers, a governor, and a police chief.[5]
[5] Common Claims, Afghanistan, Country of Origin Information Services Section (COISS), Effective from 13 December 2024
The assessment of the situation of Hazara is difficult to distil due to many other factors impacting Taliban actions including the targeting of former security forces personnel or property dispute victims who may also have been Hazara muddying any understanding of the motivation for the harm as well as reasons of general bureaucratic blockages as opposed to delays and challenges being for reasons of ethnicity.[6]
[6] ibid
The father claimed that he communicated with his family living in Afghanistan and their feedback was that they can’t speak freely about the persecution they face, and his former workers tell him that they have ‘lots of problems’. I noted that he had [number range] workers and yet he was giving evidence that only one was targeted. The applicant responded that of those that were skilled and as such senior, they had all already fled.
The overarching narrative in the material contained in the DFAT Common Claims document, which compiles various sources, is that the Taliban are threatening violence rather than actually perpetrating violence against Hazara, but they are also not actively protecting Hazara (from other groups) nor protecting their rights.
A part of the harm Hazara face is due to an association between ethnicity and religion. There is an assumption that Hazara are Shia and Shia are perceived by the Taliban as well as other militant Sunni groups as apostates. The US government International Religious Freedom report notes: ‘During the year, multiple sources said the Taliban had marginalized the minority Shia Muslim population in an effort to force them to leave the country.’[7]
[7] >
The father said that whereas before he didn’t have a problem as a Shia now there are instances where Shia are forced to convert to Sunni Islam.
Beyond being Hazara and Shia, the applicant is the son of a man who owned a company that had provided services to [international agencies and] embassies. She is also an adult female and as such faces discriminatory treatment by society and the authorities.
Regarding the risks arising from contracting to Western countries, many Western governments established procedures for the evacuation of individuals and families who supported Western efforts in Afghanistan. The Australian government’s program was the Locally Engaged Employee program which recognised the risks facing locally engaged Afghans who supported Australia.
Recent reporting by DFAT indicates that the Taliban has targeted Afghans with links to the former government and its security forces as well as to the international community.[8] But again in line with the lack of clarity on the situation on the ground, some reporting suggests that for low level individuals who were involved in a technical capacity they faced a low level of risk.[9] The Netherlands Ministry of Foreign Affairs summed it up as, ‘there was a high degree of arbitrariness, and in any case individual actions and the settlement of old scores and personal feuds sometimes occurred. The risk that an individual faced depended mainly on the local Taliban actors and, if they wanted revenge, for whatever reason, that person would not be safe.’[10] Based on the above information I find that people with low-level or distant relationships with the Western embassies and agencies, face minimal risks.
[8] Common Claims
[9] ‘DFAT Thematic Report on Political and Security Developments in Afghanistan (August 2021 to January 2022)', Department of Foreign Affairs and Trade (DFAT), 14 January 2022, Section 3.30,
[10] ‘General Country of Origin Information Report Afghanistan (June 2023)', Netherlands Ministry of Foreign Affairs, 30 June 2023, p.68,
With regards to the treatment of women, the reporting on the situation is less opaque. Women are severely limited in their freedom of movement, income opportunities, and education. They have fewer legal rights. In this scenario the applicant faces limitations on her freedom.[11]
[11] >
The applicant claimed that of her cousins who continue to live there the female children are not allowed to go to school or university, nor can they go out freely without a man.
Amnesty International provided a brief summary of the situation in 2023, which while dated, remains strongly informative on the situation as there is no information to suggest an improvement of women’s rights:
The Taliban’s draconian restrictions on the rights of women and girls, together with the use of arbitrary arrest and detention, enforced disappearance and torture and other ill-treatment, were found by Amnesty International and the International Commission of Jurists (ICJ) possibly to amount to the crime against humanity of gender persecution.
In April, the Taliban extended the ban on women working outside the home to include jobs with the UN, creating additional challenges in delivering humanitarian assistance. Bans remained on women working in the public sector, except in areas such as healthcare, primary education, or specific security institutions such as airports or women’s prisons. Women were banned from appearing in public alone or travelling for more than 72km without a male chaperone. Beauty salons were forcibly closed from July, impacting some 60,000 women-owned businesses, according to UN reports.
The ban on women participating in sports activities, or visiting public parks, continued. In some provinces, including Herat, the Taliban authorities reported introducing additional localized restrictions such as banning lone women from going to restaurants.
Restrictions on girls’ education expanded. In addition to the ban on girls’ enrolment in education beyond primary school, in June international NGOs, including programmes led by UNICEF, were banned from providing community-based education and were requested to transfer programmes to local organizations. Nearly 4,500 women were reportedly dismissed from jobs in education in June and July.[12]
[12] Amnesty International, Afghanistan 2023. type="1">
I note that this factor refers to ‘persecution’. Section 5J includes a definition of persecution as being ‘persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion.’ In considering the above fears, I am satisfied that the harm arising from being Hazara and Shia is for reasons of race and religion and therefore amounts to persecution.
I now turn my mind to consider whether ‘female’ is a particular social group in the context of Afghanistan.
When a person claims to fear being persecuted for reasons of their membership of a particular social group, the existence of such a group and the person’s membership of it is to be determined in accordance with s 5L. It provides that a person is to be a treated as a member of a particular social group (other than the person’s family) if a characteristic, other than a fear of persecution, is shared by each member of the group and the person shares, or is perceived as sharing, that characteristic. Further, that characteristic must be innate or immutable, or must be so fundamental to a member’s identity or conscience that the member should not be forced to renounce it, or it must distinguish the group from society.
With regards to female as a particular social group, the characteristic that is shared is not the fear of harm. Female, being defined in the cultural context of Afghanistan as persons having a reproductive system, is a characteristic shared by each of the group. This characteristic is innate and immutable. As such I find that ‘female’ is a particular social group and as such any harm that arises is persecution.
In considering the ‘degree of persecution to which the applicants are subject in the applicant's home country’, I place considerable weight to the applicant’s situation when considering whether there are compelling reasons for giving special considerations to granting the applicant a permanent visa.
the extent of the applicant's connection with Australia
The applicant married an Australian citizen in March 2024. She is living with her husband. He is an apprentice [occupation 1]. She is planning to study [at a named college] if granted a visa but cannot currently as she would have to pay the international student fee.
Her and her husband are said to be close to relatives already living in Australia. The Tribunal received submissions by the applicant’s cousins who are permanent residents of Australia. They wrote positively of the ties that they have with the applicant’s biological family. She described having 200 people attend their wedding in Melbourne.
In considering the ‘the extent of the applicant's connection with Australia’ I place considerable weight to the applicant’s situation of being married to an Australian citizen and being integrated into the community as reflected by the support letters and the number of people who attended the wedding. When considering whether there are compelling reasons for giving special considerations to granting the applicant a permanent visa.
whether or not there is any suitable country available, other than Australia, that can provide for the applicant's settlement and protection from persecution
The applicant’s lived experiences in Türkiye was presented to the Tribunal by the applicant and the witness. The witness said that he tried to set up a business but didn’t see a way. He said that the majority of those in a similar situation to him work in other countries such as UAE or Germany or have businesses there and support family members in Türkiye. He said that he couldn’t do that because he didn’t have a large enough business to support his family.
He said that as citizens they had access to government services such as the health system, but he added that it is very expensive, albeit partly covered by the government. He said that they did not have access to social security in Türkiye.
He felt that because there are lots of migrants in Turkey, society treats them all the same, whether they are legal or illegal. He described the discrimination he encountered: if you can’t speak Turkish people won’t help you, if you establish a business, they won’t buy from you. He said that there is a culture in Turkey of buying from Turks and not from others.
The applicant recalled how in Türkiye you are always required to carry your documents with you as proof of your identity and status. The inference being that there is a risk to the applicant were she not to be carrying her identity to be treated as a migrant or an illegal migrant.
The relevant considerations under this section are whether Türkiye can provide for the applicant’s settlement and protection from persecution. With regards to settlement, the applicant did not dispute that they have the same rights to settle that are afforded to other citizens of Türkiye.
The representative raised the wording of subclause 201.222(c) noting that it refers to a ‘suitable country’ and for this term to have any meaning it cannot be a simple assessment of whether the applicants have citizenship that provides for settlement and protection from persecution but rather whether the country is suitable in other ways.
I accept that the term suitable needs to carry some purpose in this context. In considering this I adopt the approach that there is a need to consider the suitability in the context of settlement and any persecutory elements.
The representative argued that the information provided by the applicant is indicative of Türkiye not being ‘suitable’ both in terms of settlement, referencing the prejudices in business as well as in persecution.
Country information was provided including a recent study that showed the prevalence of negative perceptions towards Afghan refugees and migrants in Turkey. The following was extracted from the research report:
prevalence of negative perceptions about, dehumanisation of, and racism towards Afghan refugees in Turkey mainly due to perceived realistic, symbolic, demographic, security, moral, and health threats from them…Afghan immigrants in Turkey are perceived as economic and safety threats by host society members, and the host society members’ attitudes convey prejudice and discrimination towards them.
In other parts of the report the authors found perceptions of Afghans most aligned with ‘ugly, disgusting, or even monsters.’
The representative noted that Türkiye is involved in politicised mass deportations. But I find that the applicant holds citizenship, as such this would not be a risk she faces, though it does add to evidence of a societal prejudice against her. The representative noted that the government has deported documented Afghans as well as undocumented Afghans, but without further information this would reasonably be read as documented non-citizens as opposed to Turkish citizens of Afghan heritage as is the case of the applicant.
In addition, the applicant provided country information that indicates that an opposition political party has filed a lawsuit to challenge the constitutional validity of the granting of citizenship to foreigners when purchasing property. I do not place any weight on the possible outcome of the case. It would be speculative without further assessments or analysis by experts in the field, nevertheless I accept that it is a further example of the attitudes towards foreigners and particularly those who were able to obtain citizenship based on the reduced threshold of investment.
The representative highlighted language, negative attitudes, social exclusion, and overt, systemic discrimination against Afghans as a basis to find that Türkiye was not a suitable country.
In considering this factor, I note that the legislation’s introduction of the subjective consideration of suitability leads to the factor carrying a wider spectrum of weight as opposed to a more binary assessment of whether the applicant has an alternative citizenship or not. I accept that the applicant faces hardships while in Türkiye and had she remained, these hardships would have persisted. She would have had to learn the language, start from the lowest socio-economic rung, develop friendships and connections, and assimilate into Turkish society at the expense of her own sense of identity all in the face of prejudice. But I place limited weight on these hardships in that such challenges are not uncommon around the world to varying degrees and yet this doesn’t make host countries unsuitable for migrants. When placing weight on this factor, I find that there is a suitable country available, other than Australia, that can provide for the applicant settlement and protection from persecution but place moderate weight against there being compelling reasons.
the capacity of the Australian community to provide for the permanent settlement of persons such as the applicant in Australia
The representative raised in her submissions a nuanced understanding of how this factor should be considered referencing Plaintiff M64-2015 v Minister for Immigration and Border Protection[13] in which four of the five justices in a joint decision wrote:
The issue is not whether arrangements can be made to feed, clothe and house the Visa Applicants by relying upon the support of the plaintiff's carer and the local Hazara community. The issue is as to the capacity of the Australian community to provide for their permanent settlement in Australia. Clause 202.222(2) authorises the decision-maker to consider a wide range of matters which bear upon their successful absorption into the Australian community, including, but not limited to, their likely ability to support themselves, and the effect that the exercise of that ability is likely to have upon others in the community. Concerns such as these are comprehended in the notion of "provid[ing] for ... permanent settlement ... in Australia", that is, as members of the Australian community. These concerns are not apt to be resolved by arrangements for the provision of accommodation and support to the Visa Applicants.
[13] Plaintiff M64-2015 v Minister for Immigration and Border Protection [2015] HCA 50 (17 December 2015)]
The applicant’s representative had argued that the Australian government facilitated the evacuation and then made available the subclass 449 visa to locally employed Afghans fleeing the Taliban and that this is indicative of the Australian community being able to provide for the permanent settlement of persons such as the applicant. In Plaintiff M64-2015 the issue of considering ‘available spaces’ was deemed as a possible relevant consideration.
As the wording in cl.201.222 presupposes a situation in which the applicants have not already lived in Australia whereas the applicant in this matter has for over three years, the consideration of the question of the capacity of the Australian community to provide for the permanent settlement of persons such as the applicants is largely answered in the affirmative. The applicant has is married and lives in a household where the husband is working and earning an income in the private sector, she is planning on continuing studies, they are a part of the social fabric. Persons such as the applicant require minimal support and as such the capacity of the Australian community to support such persons is very high.
There being minimal reasons to believe that there isn’t the capacity within the Australian community to provide for the permanent settlement of persons such as the applicant, I place moderate weight in favour of there being compelling reasons.
Considerations
The question to be considered is whether I am satisfied that there are compelling reasons for giving special consideration to granting to the applicant a permanent visa having regard to the four factors engaged with above. Neither of the factors are identified as being primary or having primacy over another. In considering them as a whole I note that the applicant faces a high degree of persecution in her home country and as such I placed considerable weight in favour of there being compelling reasons to give special consideration to granting the visa. Similarly, when it comes to the connections with Australia, I placed considerable weight. With regards to there being a suitable country that can provide the applicant settlement and protection from persecution, I found that there was a suitable country and as such placed moderate weight against there being compelling reasons. With regards to the Australian community’s capacity to provide for the permanent settlement of persons such as the applicant, I note that she has already proven that the capacity is very high as persons such as the applicant require little from Australia and as such, I placed moderate weight in favour of there being compelling reasons. When considered as a whole, I am satisfied that there are compelling reasons for giving special consideration to granting to the applicants a permanent visa.
DECISION
The Tribunal sets aside the decision under review and remits the application for a Humanitarian Subclass 201 visa for reconsideration in accordance with the order that the applicant meets cl 201.222 of Schedule 2 to the Regulations.
Date(s) of hearing: 5 February 2025
Representative for the Applicant: Ms Sarah Shnider
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