AAM16 and Minister for Immigration and Anor
[2016] FCCA 3335
•9 November 2016
FEDERAL CIRCUIT COURT OF AUSTRALIA
| AAM16 & MINISTER FOR IMMIGRATION & ANOR | [2016] FCCA 3335 |
| Catchwords: MIGRATION – Protection (class XA) visa – Administrative Appeals Tribunal – judicial review – no jurisdictional error established. |
| Legislation: Migration Act 1958 (Cth), ss.36, 422B |
| Cases cited: Tran v Minister for Immigration & Multicultural & Indigenous Affairs [2004] FCAFC 297 |
| Applicant: | AAM16 |
| First Respondent: | MINISTER FOR IMMIGRATION & BORDER PROTECTION |
| Second Respondent: | ADMINISTRATIVE APPEALS TRIBUNAL |
| File Number: | BRG 5 of 2016 |
| Judgment of: | Judge Howard |
| Hearing date: | 9 November 2016 |
| Date of Last Submission: | 9 November 2016 |
| Delivered at: | Brisbane |
| Delivered on: | 9 November 2016 |
REPRESENTATION
| Counsel for the Applicant: | Mr Jones |
| Solicitors for the Respondent: | Sparke Helmore |
ORDERS
That the application filed on 4 January 2016 be dismissed.
That the Applicant pay the costs of the First Respondent fixed in the amount of $5,800.00.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT BRISBANE |
BRG 5 of 2016
| AAM16 |
Applicant
And
| MINISTER FOR IMMIGRATION & BORDER PROTECTION |
First Respondent
ADMINISTRATIVE APPEALS TRIBUNAL
Second Respondent
EX TEMPORE
REASONS FOR JUDGMENT
A.These reasons were delivered ex tempore on 9 November 2016 and have been settled and corrected for grammatical errors in order to convey the precise intention of the Court.
The court has before it today an application for judicial review of a decision of the Refugee Review Tribunal. That decision is dated 7 December 2015. That tribunal is now known as the Administrative Appeals Tribunal. The applicant is represented by Mr Jones of counsel. The applicant is a citizen of Afghanistan. He arrived in Australia in an unauthorised manner by sea on 17 July 2012. At the time of his arrival he was only 17 years of age. He applied to the relevant Commonwealth minister for a visa and that first application was made in December 2012. On 15 July 2013, a delegate of the first respondent Minister refused to grant to the applicant a Protection (Class XA) visa. On 18 July 2013, the applicant filed an application for review to the Refugee Review Tribunal. A hearing took place on 7 May 2015 and the applicant appeared and was assisted by an interpreter as well as a representative (whom I presume to be a migration representative). After the hearing on 7 May 2015, there was some further material forwarded to the applicant for comment, which seems to have taken place in about October of 2015. In any event, on 7 December 2015 the tribunal made a decision whereby it affirmed the decision of the delegate. On 4 January 2016, the applicant filed an application in this Court for judicial review of the tribunal’s decision.
Initially there were three grounds of review contained in the application filed on 4 January 2016. Those grounds are as follows:-
“1. The Second Respondent made a jurisdictional error by taking into account irrelevant material.
Particulars:
a) Paragraph 4 contains a reference to a departmental file note of an entry interview which was not conducted under oath or with appropriate procedural fairness.
2. The Second Respondent made a jurisdictional error by demonstrating apprehended bias.
Particulars:
a) At paragraph 81 the Second Respondent states that is not prepared to give him the benefit of the doubt.
3. The Second Respondent made a jurisdictional error by breaching procedural fairness.
Particulars:
a) At the Hearing, the Second Respondent did not allow the applicant to provide complete verbal submissions owing to lack of time.”
I note that the applicant has abandoned ground number 2. The Court is therefore required to consider the remaining grounds.
The first ground refers to the tribunal or contends that the tribunal took into account material that was irrelevant, and in particular refers to a departmental file note of an entry interview that had not been conducted under oath or with appropriate procedural fairness. A review of the tribunal’s decision which is contained in the Court book does indicate that the entry interview was referred to. It doesn’t appear to have been referred to in any significant way. The relevant decision of the tribunal dated 7 December 2015 commences at page 310 of the Court book. The Court book is exhibit 1.
In any event, I note what was stated in a decision entitled SZTBJ v Minister for Immigration [2015] FCA 580 at paragraph 95, where the Court reiterated that for a jurisdictional error to actually be established on the basis that a tribunal has taken into account an irrelevant consideration, it has to be shown that the consideration itself is one which the tribunal or a decision maker is forbidden or prohibited from taking into account. That is not the case here. The tribunal has not committed any jurisdictional error by referring to or considering the applicant’s entry interview. In a decision entitled Tran v Minister for Immigration & Multicultural & Indigenous Affairs [2004] FCAFC 297, the point was well made that it is a matter for the tribunal in each case to determine which material it considers to be relevant, and it’s also a matter for the tribunal to give such material the appropriate weight that it sees fit. The applicant has not been able to show any jurisdictional error in relation to ground number 1.
As I noted earlier, ground number 2 has been abandoned, so the Court has to turn its mind to ground number 3, and in doing so I am specifically having regard to the written submissions provided by Mr Jones, counsel on behalf of the Applicant, those written submissions having been filed on 28 October 2016. The grounds upon which the applicant relies today, the remaining grounds, whilst they are contained in the application filed 4 January 2016 – it should be noted that I am having regard to those grounds along with the written submissions filed 28 October 2016.
The essence of ground 3 relates to what is said to be a failure to accord procedural fairness to the applicant, and it is said that this amounted to jurisdictional error. In the Migration Act 1958 (“the Act”) itself at section 422B, it is stated:-
“422B Exhaustive statement of natural justice hearing rule
(1) This Division is taken to be an exhaustive statement of the requirements of the natural justice hearing rule in relation to the matters it deals with.
(2) Sections 416, 437 and 438 and Division 7A, in so far as they relate to this Division, are taken to be an exhaustive statement of the requirements of the natural justice hearing rule in relation to the matters they deal with.
(3) In applying this Division, the Tribunal must act in a way that is fair and just.”
That section itself is headed “Exhaustive Statement of Natural Justice Hearing Rule”. In numerous decisions including SZCIJ v Minister for Immigration and Multicultural Affairs & Anor [2006] FCAFC 62 and Minister for Immigration and Multicultural Affairs v Lay Lat [2006] 151 FCR 214 it was pointed out that the tribunal is not required to accord to an applicant procedural fairness as that is understood at common law. The tribunal must only comply with the provisions of division 4 of part 7 of the Act. The applicant in this case was, of course, invited to appear before it in the hearing which went ahead on 7 May 2015. I have not been taken to any evidence that would convince this Court that the applicant had not been given a real and meaningful opportunity to put forward his arguments, his case, and his view at the hearing that took place on 7 May 2015. In this regard I note a decision of the Federal Court entitled Minister for Immigration and Multicultural and Indigenous Affairs v SCAR (2003) 128 FCR 553. The hearing which went ahead in May 2015 lasted approximately three hours – this is noted in the Court book itself – and not only were submissions made on behalf of the applicant at the hearing but subsequently there were further submissions provided. There is a reference, indeed, in the grounds noted in the application in paragraph 3(a) to a lack of time, but I do note the Court has before it an affidavit filed 4 November from Michelle Forshaw, who has annexed to that affidavit the transcript. What is apparent from the transcript is the mention of the time constraint in fact related to the interpreter, who apparently had – was supposed to be at another hearing at 1:00pm and was already running late by five minutes. But the member of the tribunal who was conducting the hearing said that they needed a further 20 minutes, and the matter was temporarily adjourned so that a proper arrangement could be made for the interpreter to remain longer, and that arrangement was made. And not only that: I note that at page 66 of that transcript, the tribunal informed the applicant that if there was something further that he wanted to add, that such further information or submission could be included in a post-hearing submission. Furthermore, the tribunal member specifically asked the applicant’s representative whether they would like to make a further written submission after the hearing, and that representative indicated that they would like to do so. And this further submission was provided on behalf of the applicant by the applicant’s representative so that the ground so far as it relates to a breach of procedural fairness and so far as that ground also relates specifically to what was said to be a failure to allow the applicant to provide complete verbal submissions owing to a lack of time – I do not consider that the applicant has been able to make out or show jurisdictional error on the basis of that ground or those grounds.
The tribunal did in fact comply with the statutory obligations relating to procedural fairness which are contained in division 4 of part 7 of the Act. In the written submissions provided on behalf of the applicant and in oral submissions today, reference is made to what is said to be a series of assumptions made by the tribunal and particularised as:-
“…
(i) as to the ineptitude of the these unnamed persons when they attempted to kidnap the Applicant on two occasions, the first as he was leaving his school and later that night, when they attended the family’s home, and
(ii) the soundness or otherwise of the decisions made by the Applicant’s father, in respect to the land and allowing his wife to answer the door after having been told by the Applicant of the earlier unsuccessful kidnapping attempt.”
The assumptions that are referred to in the applicant’s submissions in fact form part of the credibility findings made by the tribunal. The finding that was made was a broad finding, drawing together and stating essentially the credit findings made by the tribunal against the applicant. Paragraph 82 of the tribunal’s decision states:-
“Accordingly, for all of the above reasons, in light of its findings that he was not a reliable witness, the Tribunal has no confidence in accepting, and does not accept, that his evidence about what occurred to him in Afghanistan was based on his personal or actual experiences, and considers it was fabricated to create a claim to be owed protection. On the evidence before it, the Tribunal does not accept that he or his father or any other member of his family had come to the adverse attention of mafia criminals associated with the warlord, Abdul Rasul Sayyaf, or any other person or group, or that those people, or any other person or group, had an adverse interest in him, or his family, for reasons relating to land owned by his family, or any other reason. On the evidence before it, the Tribunal does not accept he or his father or mother were ever threatened or harmed in any way or that he was subjected to an attempted abduction or any other adverse treatment, prior to his departure from Kabul in or around April 2012, or that he and his family had left their home prior to his departure for the reasons claimed.”
That is a comprehensive conclusion or summary of the credit findings made by the tribunal against the applicant. This Court, of course, cannot on a judicial review application conduct a merits review. The findings made by the tribunal, in fact, were brought to the applicant’s attention at the hearing, and this was specifically noted in paragraph 79 of the tribunal’s decision.
“79. As discussed with the applicant at the hearing, the irregularities in his evidence and claims caused the Tribunal to have doubts about the reliability of his evidence and the credibility of his claims. Considered cumulatively, the concerns the Tribunal holds about his credibility on these matters lead it to find that his evidence about key aspects of his claims was not reliable, and that the account of events on which his protection claims are based is not credible. As discussed above, his evidence about a number of matters was inconsistent and contradictory over time, and, in a number of aspects, vague and lacking in detail, and the Tribunal considers that, on at least one occasion, he was willing to adjust and adapt his evidence to fill in perceived gaps in his claims and reconcile otherwise inconsistent statements. Further, at times he was confused and uncertain in the answers he gave to questions which, if the events claimed had taken place, the Tribunal would have expected clearer answers, and, at other times, he was hesitant in giving responses and often did not provide clear or direct answers, but gave vague and general responses, and, key aspects of his claims were implausible and difficult to understand or believe.”
I note in particular the first sentence or the first two sentences where it was stated by the tribunal:
“79. As discussed with the applicant at the hearing, the irregularities in his evidence and claims caused the tribunal to have doubts about the reliability of his evidence and the credibility of his claims. Considered cumulatively, the concerns the tribunal holds about his credibility on these matters led it to find that his evidence about key aspects of his claims was not reliable, and that the account of events on which his protection claims are based is not credible…”
I note further what was stated by the tribunal in paragraphs 80 and 81 of the decision. In those paragraphs the tribunal stated:
“80. In making these findings, the Tribunal has allowed for the possibility of discrepancies arising because of genuine lapses of memory, nervousness and the matter in which responses can differ depending on the nature and manner of which a question is asked, and has also taken into account the effect of his relatively young age and lack of education as well as the passage of time on his ability to recount his experiences. It is also sensitive to the various cultural differences that can impact on an applicant’s responses to questioning, as discussed in the Tribunal’s ‘Guidance on the Assessment of Credibility’ and to the various submissions made by his migration agent. However, the Tribunal does not accept that any of these factors explain or excuse the concerns which, cumulatively, have led it to find that he was an unreliable witness.
81. In making these findings, the Tribunal has carefully considered the submissions made by his agent, including that it should afford him the benefit of the doubt with regard to the number of anomalies and irregularities in his evidence over time, because, in a number of aspects, his evidence was consistent over time; however, for all the above reasons, including the nature and number of the irregularities in his evidence, and the implausible aspects of his claims, the Tribunal is not prepared to give him the benefit of the doubt and, on the evidence before it, does not accept that his experiences in Afghanistan or in Australia, have affected his ability to recollect events, or that his evidence has been incorrectly interpreted by the qualified interpreters who have been used over time to assist him give his evidence.”
In particular I make mention of the fact that the tribunal took into account the applicant’s relatively young age and his lack of education, as well as the passage of time on his ability to recount his experiences.
I note, for instance, what was stated by the High Court in Minister for Immigration and Citizenship v SZMDS (2010) 240 CLR 611, in particular, per Crennan and Bell JJ at paragraph 130. In that paragraph, their Honours stated:
“130. In the context of the Tribunal’s decision here, “illogicality” or “irrationality” sufficient to give rise to jurisdictional error must mean the decision to which the Tribunal came, in relation to the state of satisfaction required under s 65, is one at which no rational or logical decision maker could arrive on the same evidence. In other words, accepting, for the sake of argument, that an allegation of illogicality or irrationality provides some distinct basis for seeking judicial review of a decision as to a jurisdictional fact, it is nevertheless an allegation of the same order as a complaint that a decision is “clearly unjust” or “arbitrary” or “capricious” or “unreasonable” in the sense that the state of satisfaction mandated by the statute imports a requirement that the opinion as to the state of satisfaction must be one that could be formed by a reasonable person. The same applies in the case of an opinion that a mandated state of satisfaction has not been reached. Not every lapse in logic will give rise to jurisdictional error. A court should be slow, although not unwilling, to interfere in an appropriate case.”
Other conclusions reached by the tribunal in the current case: conclusions which no rational or logical decision maker could arrive at on the same evidence.
But in relation to the question of, for instance, the applicant’s claim for protection based upon whether, for instance, he or his family would be subjected to the adverse attention of criminal groups for reasons relating to land, I do not consider that the conclusions reached are such that one would say that the conclusion was illogical or irrational. They are not conclusions that one could say no rational or logical decision maker could arrive at on the same evidence. The evidence, of course, or the conclusions on credibility to which I have referred, were merely summarised in paragraph 82, and there were, as I have already indicated, other findings on credit. It has to be kept in mind that such a tribunal is not obliged to accept in an uncritical way an applicant’s claims. This point was made as long ago as 1985 in Prasad v Minister for Immigration and Ethnic Affairs (1985) 6 FCR 155.
The conclusions that were reached by the tribunal in relation to, for instance, the claimed kidnappings or attempted kidnappings, one would have to say, were reasonably open to it. The claim related to a notorious war lord known as Abdul Rasul Sayyaf, and, as explained by the tribunal in its decision at paragraph 69:
“69. …It is difficult to believe that, had such a notorious warlord intended to abduct the applicant to use him as a tool to blackmail his father into selling or giving him the disputed land, that he or his agents would have made such a clumsy attempt to do so. The Tribunal considers it highly improbable that, had such people intended to abduct him, they would have been so easily put off by the noise and shouts from his friends and other bystanders, and that they would have allowed him to so easily pull away and run off. In the Tribunal’s view, those circumstances are not consistent with the conduct it is reasonable to expect from such violent and ruthless mafia criminals.”
Furthermore, at paragraph 70 of the tribunal’s decision, the tribunal came to the conclusion that, in its view, the applicant’s account of what had occurred at his home later that evening was implausible.
The tribunal noted at paragraph 64 of its decision that the applicant’s evidence had been vague and general in detail. For example, he did not provide specific detail about the exact location of the land or when it became a contentious issue. Having referred to that, the tribunal then did go on to say, nevertheless, that in the light of his relatively young age at the time those incidents were alleged to have occurred and the fact that he didn’t claim any involvement in his father’s business affairs, it was plausible that the applicant’s father may not have disclosed those specific details to him relating to the location of the land and other issues relating to the land, so that the tribunal, on a reading of this decision, listened carefully to the applicant, took into account what he had to say, but concerning key elements of the applicant’s claim so far as – in particular they relate to his claims for protection, the tribunal made credit findings against the applicant. Certainly the tribunal was not impressed with the applicant’s evidence in relation to his attempts to make contact with his family since he arrived in Australia.
These credit findings made by the tribunal were reasonably open to it. This court, as I said earlier, is not permitted to embark upon a merits review.
As I noted earlier, the summary or the cumulative assessment of the applicant’s credibility which the tribunal made has been stated or summarised in paragraph 82 of the tribunal’s decision. Reference has been made to a decision of the High Court entitled Minister for Immigration and Border Protection v SZSCA (2014) 254 CLR 317. In that particular case, the High Court concluded that the relevant tribunal had fallen into error by not considering whether it would be reasonable to expect the applicant in that case to remain and work in Kabul. The circumstances of that particular case were such that the applicant in SZSCA was a truck driver who was or could be required to travel outside of Kabul.
The tribunal in the present case before this Court from paragraph 107 specifically referred to the High Court’s decision in SZSCA. In the case currently before the court, the applicant lived in Kabul from the age of six. He lived there for ten years prior to departing Afghanistan. There doesn’t appear to be any evidence or claim made by the applicant that he would be required potentially to leave Kabul, and this question really revolves around the question of reasonableness in the light of the High Court’s decision in SZSCA.
In paragraph 107, the tribunal noted that the applicant had no family outside of Kabul, and the tribunal concluded that there was no reasonable or credible reason to consider that in the applicant’s own circumstances he would need to leave Kabul for work or educational opportunities, and the tribunal concluded that it was reasonable, in the circumstances of this particular case, for the applicant to remain living in Kabul to re-establish his life and to seek employment.
The tribunal also took into account, of course, the refugee claims and the complementary protection claims, and in doing so had regard to the fact that the applicant’s ethnicity is Hazara. It took into account his religion, namely a Shia Muslim. It noted the country information and concluded that the government of Afghanistan maintained effective control of Kabul. The tribunal concluded that the applicant did not meet the refugee criterion in section 36, subsection 2(a) of the Migration Act, and then went on to consider the complementary protection criterion in section 36, subsection (2)(aa), and from paragraph 110 onwards the tribunal considered those questions, and there really doesn’t seem to be any argument put forward that the tribunal fell into jurisdictional error when considering those claims and those sections of the legislation. To put it another way, certainly the tribunal’s decision does not disclose any jurisdictional error in considering these claims.
The tribunal’s conclusions at paragraph 107 could not be said to be unreasonable in the sense that term was used or referred to in SZSCA. There is a letter at page 250 of the Court book and another copy of it might have been sent directly to the applicant at page 252. Those letters indicate that a DFAT Afghanistan country information report was being provided then to the applicant as well as a DFAT thematic report relating to the conditions in Kabul. Those reports were provided for the consideration of the applicant and his representative and an opportunity was given for written comments to be received by 16 October 2015.
The Court book in fact does contain the DFAT country information report about Afghanistan, which is dated 18 September 2015, but the court book erroneously includes, it seems, a DFAT thematic report relating to the Hazaras in Afghanistan dated 8 February 2016. On the face of it, that could not have been the document that was forwarded to the applicant in October 2015, the date of the document relating to the Hazaras in Afghanistan being 8 February 2016. Once that error was identified the Court requested Mr Kyranis, the solicitor for the first respondent, to obtain a copy of the correct report.
Paragraph 3.15 of that document is a DFAT thematic report about the conditions in Kabul dated 18 September 2015. It notes, for instance – and I think this was actually specifically referred to in the decision – that the department of foreign affairs and trade had assessed that because of Kabul’s size and diversity, returnees were unlikely to be discriminated against or subjected to violence on the basis of ethnicity or religion.
A review of that DFAT thematic report about the conditions in Kabul dated 18 September 2015, and in particular that paragraph to which I referred earlier, namely paragraph 3.15, strengthens in my own mind the conclusion I reached: that it cannot be said that the decision of the tribunal in this case was one that no rational or logical decision maker could arrive at on the same evidence. The tribunal went to some length in discussing this particular report. I note paragraph 87 of the decision where the tribunal specifically states:-
“DFAT advised that it had no evidence to suggest that Hazaras are systematically targeted in insurgent attacks on the basis of their ethnicity alone, and that with the exception of kidnapping Hazaras, are not currently at any greater risk of violence than other ethnic groups in Afghanistan.”
The point being the tribunal specifically referred or considered that aspect of the DFAT advice, but in the overall consideration by the tribunal of the DFAT country information particularly from and including paragraphs 87, 88, 89, 90, right through up to and including paragraph 101 and, in fact, beyond there, the tribunal carefully considered the independent country information and took into account the applicant’s Hazara ethnicity. The tribunal took into account the applicant’s religion, namely a Shia Muslim and considered questions relating to indiscriminate attacks on Hazaras. I note paragraph 91 of the tribunal’s decision where the tribunal stated:-
“91. Professor Alessandro Monsutti stated in January 2012 that insecurity in Kabul is the result of indiscriminate attacks, and Hazaras are not less safe than any other ethnic group.”
I note specifically what was stated in paragraphs 92 to 95. In those paragraphs the tribunal stated:-
“92. The Tribunal accepts that there have been incidents where Hazara Shi’as have been targeted, where ethnicity and religion would appear to be a factor, and that ISIS have started operating in Afghanistan. However, the available information does not indicate that all Hazara Shi’as in Kabul face a real chance of serious harm now or in the reasonably foreseeable future from these Sunni groups or anyone else.
93. DFAT has commented that Kabul’s size and diversity means that there are large communities of almost all ethnic, linguistic and religious groups in the city and that returnees are unlikely to be discriminated against or subjected to violence on account of their ethnicity or religion. DFAT observed that there are many Shia mosques in the city. This information suggests that there is a large Hazara Shia community which the applicant can reintegrate into.
94. The independent country information indicates that there are no laws or Government policies that discriminate against Shi’a Muslims and that, broadly speaking, there is little community prejudice (i.e. societal discrimination) that would limit opportunities for Shi’a Muslims in daily life on the basis of their Shi’a faith. The country information further indicates that, although there is societal discrimination on the basis of ethnicity, it is most commonly manifested in forms of nepotism within ethnic and religious communications and that positive societal discrimination in favour of family, tribal or ethnic group members is common. DFAT has also commented that ethnic based violence in Kabul is rare, and that Sunni-Shia violence was infrequent in Afghanistan. In making that assessment, DFAT took into account the Ashura Day bombing in Kabul of December 2011, the attack on an Ismaili Shi’a cultural centre in Kabul in February 2014, which killed on security guard, and the attack by gunmen on a Sufi mosque in Kabul in March 2015 that killed 11 worshippers.
95. The Tribunal accepts that the applicant is a Shi’a and will attend mosque and religious events; however, considered as a whole, the available country information indicates that the chance he will be seriously harmed by attending a mosque or a religious event is remote. Having carefully considered the evidence and information before it, including the various submissions of his migration agent and the reports referred to in those submissions, the Tribunal does not accept that there is a real chance that he would suffer serious harm as a result of Sunni-Shi’a sectarian violence if he returns to Afghanistan now or in the reasonably foreseeable future, or that he would be subjected to serious harm for reasons of his Shi’a faith, including by attending a mosque or a religious event, or any associated or related reason.”
I draw specific attention to paragraph 93, where the tribunal concluded that the country information suggested that there was a large Hazara Shia community which the applicant could reintegrate into in Kabul. Some reference was made during argument to a statement by the tribunal at paragraph 99 about the applicant having extensive contacts, having lived in Kabul for over 10 years. The comment or that sentence, which appears at the end of paragraph 99, could hardly be said to be integral to the tribunal’s conclusions, whether that sentence is correct or not.
In order to clarify the situation, it is important for the Court to note here in these reasons for judgment that in reaching the conclusions that this court has reached concerning this particular application for judicial review, this court has not taken into account the document that was erroneously included. It is the case that I did, of course, read some paragraphs of that document during argument, but in reaching my decision that there has been no jurisdictional error identified, the court does not need to and has not taken into account the documents that had been erroneously included.
I do not consider that the applicant in this particular case has been able to demonstrate jurisdictional error on the part of the tribunal. The application is dismissed. In doing so I would reiterate and I would specifically ask Mr Jones of counsel to explain to his client the applicant, who is here today, that this Court on an application for judicial review is not at liberty to embark upon a merits review and it is very often the case that the courts make these comments and include such sentences and paragraphs in their reasons, but when an applicant is represented, the Court does appreciate the legal representatives specifically explaining to the applicant what that actually means.
I certify that the preceding thirty-four (34) paragraphs are a true copy of the reasons for judgment of Judge Howard
Date: 20 December 2016
Key Legal Topics
Areas of Law
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Administrative Law
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Immigration
Legal Concepts
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Judicial Review
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Procedural Fairness
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Natural Justice
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Jurisdiction
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