Audiburg Wine Group Pty Ltd (Migration)

Audiburg Wine Group Pty Ltd (Migration) [2019] AATA 2806 (30 May 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANT:  Audiburg Wine Group Pty Ltd
CASE NUMBER:  1714657
HOME AFFAIRS REFERENCE(S):           BCC2016/4087943
MEMBER:Karen Synon
DATE:30 May 2019
PLACE OF DECISION:  Melbourne
DECISION:The Tribunal affirms the decision not to approve the nomination.
Statement made on 30 May 2019 at 9:16am

CATCHWORDS
MIGRATION – Employer Nomination – approval of nominated position – Callover invitation – nominated contact person – ceased office as company secretary and director – no response to invitation to provide information – not entitled to appear before the Tribunal – Marketing Specialist – genuine position – role to be performed by nominee – undertaking less-skilled tasks – limited and out-dated information – decision under review affirmed
LEGISLATION
Migration Act 1958 (Cth), ss 140GB, 140GBA, 359C, 360, 363A
Migration Regulations 1994 (Cth), rr 2.72, 2.73
CASES
Cargo First Pty Ltd v MIBP [2016] FCA 30
Hasran v MIAC [2010] FCAFC 40

STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Immigration and Border Protection on 20 June 2017 to refuse to approve the applicant’s nomination under s.140GB of the Migration Act 1958 (the Act) and r.2.72 of the Migration Regulations 1994 (the Regulations).
The applicant applied for approval on 4 December 2016. A nomination of an occupation for a Subclass 457 visa is made under s.140GB of the Act and r.2.73 of the Regulations. Regulations 2.72(3) to (12) prescribe the criteria that must be satisfied for the Minister to approve a nomination by a person. These criteria are extracted in the attachment to this decision. For nomination applications made from 23 November 2013, additional criteria are specified in s.140GBA.
The delegate decided not to approve the nomination on the basis that the applicant did not satisfy 2.72(10)(f) because she was not satisfied that the position associated with the nominated occupation was genuine.
The applicant applied for review of the primary decision on 8 July 2017 and provided a copy of the delegate’s decision.
The applicant was represented in relation to the review by its registered migration agent.
The Tribunal wrote to the applicant via its representative on 11 July 2017 acknowledging the lodgement of the applicant for review. In this letter the Tribunal advised “[i]f you wish to provide material or written arguments for the Tribunal to consider, you should do so as soon as possible”. No substantive information has been received from the applicant since the time it lodged the application for review.
On 11 January 2019 the review applicant was invited to a Callover on 13 February 2019. On 27 January 2019 the representative wrote to the Tribunal asking that the Callover be postponed due to the review applicant’s contact person, Mr Lixin Shang, being overseas on 13 February 2019. The Callover was rescheduled to 6 March 2019.
On 6 March 2019 the review applicant’s representative attended the Callover during which it was explained what evidence and information about the case the Tribunal requires for it to be satisfied that all the requirements of Regulation 2.72 are met. The representative advised that Mr Lixin Shang is now the director of another company, Legend Wine Group Pty Ltd and he would seek instructions about whether this review would continue.
When, by 19 April 2019, no further advice had been received as to whether this review would continue, the Tribunal wrote to the review applicant, via its authorised recipient and registered migration agent, to seek formal advice as to the review applicant’s intention and whether the application was to be withdrawn. A response was requested by 16 April 2019.
On 16 April 2019 the Tribunal was advised that Mr Shang was “in the process to reclaim ownership and directorship of Audiburg Wine Group Pty Ltd, [h]owever because of the death of the previous owner and director…the process is having some technical delay in terms of probate arrangements”. Further time was requested to provide such information.
Relevantly on 1 May 2019 the Tribunal wrote to the review applicant, via its authorised recipient and registered migration agent, to advise that as the matter had now been scheduled for 2 Callovers, the first of which was 13 February, over 2 months before, the Tribunal would be proceeding with this matter and would issue a letter inviting the review applicant to provide all the information required to demonstrate it satisfies Regulation 2.72. In so advising it noted that the primary decision had been made over 22 months before and it believed this considerable period of time had afforded the review applicant sufficient time to organise the affairs of the company. In particular the Tribunal noted in bold:
By providing you with these documents we are taken to have given the document to the review applicant. You should ensure that the applicant is informed of this letter as soon as possible.
Later on 1 May 2019 the Tribunal wrote to the applicant, in accordance with s.359(2) of the Act, inviting it to provide “undated and current information” addressing all of the requirements in Regulation 2.72. The letter, without limiting the information that might be given, invited:
ØInformation about the identity of any person authorised to speak and make decisions on behalf of the applicant;
ØIf the applicant is a company or registered business, current and historical information about its office holders’ registration details;
ØInformation about the applicant’s current status as an approved Standard Business Sponsor or party to a work agreement;
ØInformation about the applicant directly operating an active and lawful business in Australia, and its financial position for at least the last two financial years;
ØInformation about the applicant’s current organisational structure and where the nominated position sits in relation to that structure;
ØInformation about the roles and duties of the nominated position and how they correspond to the nominated occupation’s position description in ANZSCO;
ØInformation about the base rate of pay and the terms and conditions of employment in the nominated position, including whether or not they are more favourable than those provided to an Australian citizen or permanent resident performing equivalent work in the same location;
ØInformation about the visa status of the nominee, and also about the nominee’s English language ability;
ØIf the nominated occupation is subject to an inapplicability condition (also known as a caveat), information about why the caveat does not apply in the circumstances of this case.
ØA copy of an updated signed Contract of Employment.
The invitation was sent to the review applicant via its nominated authorised recipient and registered migration agent’s email address which had been provided in connection with the review. The applicant was advised that if the information was not provided in writing by 15 May 2019, the Tribunal may make a decision on the review without taking further steps to obtain the information and the applicant would lose any entitlement it might otherwise have had under the Act to appear before the Tribunal to give evidence and present arguments.
The applicant did not provide the information within the prescribed period and no extension was requested or granted.
On 20 May 2019 the Tribunal again wrote to the review applicant, via its authorised recipient and registered migration agent, addressing this correspondence to Ling Fu Ren the listed director and company secretary of Audiburg Wine Group Pty Ltd, in the following relevant terms:
Mr Lixin Shang was nominated in the application as the contact person for Audiburg Wine Group Pty Ltd and since that time the Tribunal has been corresponding with him on behalf of Audiburg Wine Group Pty Ltd via the company’s authorised recipient and registered migration agent, Mr Boniface Town.
However on 16 May 2019 a search of ASIC records confirm that Mr Lixin Shang ceased to be the company secretary and director of Audiburg Wine Group on 8 May 2018 and that you have been listed as the sole director and company secretary since 8 May 2018. The Tribunal was not advised of this change of directorship.
On 1 May 2019 the Tribunal wrote to Audiburg Wine Group, via the company’s authorised recipient and registered migration agent, Mr Boniface Town. That letter invited updated and current information addressing all the criteria needed to satisfy Regulation 2.72 of the Migration Act. This information was invited by 15 May 2019 and in the letter Audiburg Wine Group Pty Ltd was advised that if the information was not received within the period allowed (or as extended but this was not requested), the Tribunal may take a decision on the review without taking any further action to obtain the information and Audiburg Wine Group would lose any entitlement it might otherwise have had under the Migration Act to appear before us and to give evidence and present arguments. This letter was sent, was legally required, to Audiburg Wine Group Pty Ltd via its advised authorised recipient and registered migration agent, Mr Boniface Town.
However, in light of the change of directorship, the Tribunal would like to advise that it will delay its written decision for 7 days that is until 28 May 2019, before proceeding on the basis of the evidence before it, to allow you additional time to provide any additional written evidence you would like the Tribunal to consider.
No response was received to this letter. Nor have any substantive submissions or evidence been received in the period since the Callover on 6 March 2019.
In these circumstances, s.359C applies and pursuant to s.360(3) the applicant is not entitled to appear before the Tribunal. The effect of s.363A of the Act is that if an applicant has no entitlement to a hearing, the Tribunal has no power to permit him or her to appear: Hasran v MIAC [2010] FCAFC 40. The Tribunal is satisfied that it has communicated with the applicant via its authorised recipient at the representative’s advised email address in a prescribed manner. The Tribunal has accordingly decided to proceed to decision without taking further steps to obtain the information. In making this decision the Tribunal notes that the applicant has not provided any substantive materials, written arguments or information since the lodgment of the application for review on 8 July 2017, over 22 months ago.
For the following reasons, the Tribunal has decided affirm the decision under review to refuse the nomination.
CONSIDERATION OF CLAIMS AND EVIDENCE
The issue in the present case is whether the applicant meets the criteria for approval of the nomination. The Tribunal must approve the nomination if the applicant is an approved sponsor and meets the requirements in r.2.72: s.140GB(2). The applicant must also have paid any nomination training contribution charge in relation to the nomination for which they are liable, but this liability only arises for nominations made from 12 August 2018. In addition, for nominations made from 23 November 2013, s.140GBA must be met.
Position must be genuine
Regulation 2.72(10)(f) requires that the position associated with the nominated occupation is genuine. This was considered in Cargo First Pty Ltd v MIBP [2016] FCA 30, where the Court at [34]) upheld the Tribunal’s approach of qualitatively assessing the position and comparing this with the occupation nominated in order to determine whether it was genuine.
The delegate refused the nomination because she was not satisfied that the nominated position of Marketing Specialist is what it purports to be and that when assessing the claimed duties of the position in the context of all the information provided with application, that the tasks of the nominee would align substantially with the nominated occupation. After taking into account the context of the position, the delegate noted concerns that the nominee would be undertaking non or less-skilled tasks that could be performed by a non-skilled employee, in particular maintaining relationships with existing and potential clients and liaising with suppliers for marketing materials, presentation and making.
In the absence of any submissions or evidence being provided to the Tribunal, it has considered all of the evidence provided to the department in support of the nomination application. This includes: a submission prepared by Mr Boniface which addresses the genuineness of the position, its alignment with the ANZSCO and the nature and core activates of the business; a 2015 company tax return; BAS returns for the quarters 1 July to 30 September 2015, 1 October to 31 December 2015, 1 January to 31 March 2016, 1 April to 30 June 2016 and 1 July to 30 September 2016; a profit and loss financial report for the year ending 30 June 2015; 15 photographs; a letter of support for the nominee from Mr Lixin Shang; copies of internal correspondence with clients and suppliers and sale invoices and contracts; translated copies of ‘Certificate of Authorisation” for distribution of wine in China; information about a Chinese business delegation trip to Australia; a timetable of the business events the nominee attended in 2016 and early 2017 to promote the business; a business plan dated October 2016; labour market information and an employment agreement between the applicant and the nominee dated 9 August 2016.
The Tribunal notes that the material relating the position appears to have been provided to the Department over 2 years ago and that although the above evidence was provided, this material is now substantially out of date. The applicant has not provided to the Tribunal any recent information about the need for the position or the genuineness of the position, such as information about the duties of the position and how the position fits within the size and nature of the business despite the delegate specifically raising this issue in the decision. In this respect the Tribunal notes that it stressed in its correspondence that all of the requirements of Regulation 27.27 must be satisfied at the time of decision and it required updated and current information.
The applicant did not respond, within the prescribed period, to the Tribunal's letter of 1 May 2019 inviting the provision of information which demonstrates that the nomination meets all the requirements of Regulations 2.72 including the genuineness of the position: r.2.72(10)(f). Nor has any information been received in the 2 weeks since 15 May 2019 or indeed at any stage during the review period.
The Tribunal has considered all the information available to it but does not consider it to be sufficient to satisfy the Tribunal that the position is genuine. As no additional information has been provided to the Tribunal and because the applicant has lost the entitlement to a hearing and the Tribunal was therefore not able to take oral evidence from the review applicant regarding the genuineness of the position or why the review applicant believes the position associated with the nominated occupation is genuine, the Tribunal only has limited and significantly out-dated information before it.
At the time of decision, the Tribunal is not satisfied that there is sufficient recent evidence about the nature of the position or the operations of the applicant. On the limited evidence before it, the Tribunal is not satisfied that the position associated with the nominated occupation is genuine.
For these reasons the requirements of r.2.72(10)(f) are not met.
For the reasons given above, the Tribunal is not satisfied that the applicant meets the applicable criteria for the nomination to be approved. Accordingly, the decision under review must be affirmed.
DECISION
The Tribunal affirms the decision not to approve the nomination.
Karen Synon
Member

ATTACHMENT - EXTRACTS FROM THE MIGRATION REGULATIONS 1994
2.72 Criteria for approval of nomination — Subclass 457…
(1)This regulation applies to a person who is:
(a)is any of the following:
(i) a standard business sponsor;
(ii) a person who has applied to be a standard business sponsor;
(iii) a party to a work agreement (other than a Minister);
(iv) a party to negotiations to a work agreement (other than a Minister); and
(b)a party to a work agreement (other than a Minister);
who, under paragraph 140GB (1) (b) of the Act, has nominated an occupation in relation to a holder of, or an applicant or a proposed applicant for, a [Subclass 457 visa].
(2)For subsection 140GB (2) of the Act, the criteria that must be satisfied for the Minister to approve a nomination by a person are set out in subregulations (3) to (12).
(3)The Minister is satisfied that the person has made the nomination in accordance with the process set out in regulation 2.73.
(4)The Minister is satisfied that the person is:
(a)a standard business sponsor; or
(b)a party to a work agreement (other than a Minister).
(5)The Minister is satisfied that the person has identified in the nomination the visa holder, or the applicant or proposed applicant for the visa, who will work in the nominated occupation.
(6)If the person identifies a holder of a [Subclass 457 visa] (the visa holder) for subregulation (5), the Minister is satisfied that the person:
(a)has listed on the nomination each other holder of a visa of that kind who was granted the visa on the basis of having the necessary relationship with the visa holder as mentioned in clause 457.321 of Schedule 2; and
(b)if the Minister requires the visa holder to demonstrate that he or she has the skills necessary to perform the occupation — the visa holder demonstrates that he or she has those skills in the manner specified by the Minister.
(7)For paragraph (6) (a), the Minister may disregard the fact that 1 or more persons required to be listed on the nomination are not listed, if the Minister is satisfied it is reasonable in the circumstances to do so.
(7A)In addition to subregulation (6):
(a)if:
(i)       the person identifies a holder of a [Subclass 457 visa] (the visa holder) for subregulation (5); and
(ii)      the [Subclass 457 visa] was granted after the Minister had waived the requirements of paragraph 4006A (1) (c) of Schedule 4 on the basis of a written undertaking made by the current sponsor of the visa holder (as set out in subclause 4006A (2) of that Schedule);
the Minister is satisfied that the person has provided, in writing, an undertaking that is equivalent to the undertaking made by the current sponsor of the visa holder; and
(b)if:
(i)       the person identifies a holder of a [Subclass 457 visa] (the visa holder) for subregulation (5); and
(ii)      the person has listed on the nomination a person described in paragraph (6) (a); and
(iii)     the [Subclass 457 visa] was granted to the person described in paragraph (6) (a) after the Minister had waived the requirements of paragraph 4006A (1) (c) of Schedule 4 on the basis of a written undertaking made by the current sponsor of the visa holder (as set out in subclause 4006A (2) of that Schedule);
the Minister is satisfied that the person has provided, in writing, an undertaking that is equivalent to the undertaking made by the current sponsor of the visa holder.
(8)If the nomination was made before 1 July 2010 — the Minister is satisfied that the person has provided the following information as part of the nomination:
(a)if there is a 6‑digit ASCO code for the nominated occupation — the 6-digit ASCO code;
(b)if there is no 6-digit ASCO code for the occupation, and the person is a standard business sponsor — the name of the occupation as it appears in the instrument in writing made for the purposes of paragraph (10) (a);
(c)if there is no 6-digit ASCO code for the occupation and the person is a party to a work agreement — the name of the occupation as it appears in the work agreement;
(d)the location or locations at which the nominated occupation is to be carried out.
(8A)If the nomination is made on or after 1 July 2010 – the Minister is satisfied that the person has provided the following information as part of the nomination:
(a)if there is a 6-digit ANZSCO code for the nominated occupation - the name of the occupation and the corresponding 6-digit ANZSCO code;
(b)if:
(i)       there is no 6-digit ANZSCO code for the nominated occupation; and
(ii)      the person is a standard business sponsor;
the name of the occupation and the corresponding 6-digit code as they are specified in the instrument in writing made for paragraph (10)(aa);
(c)if:
(i)       there is no 6-digit ANZSCO code for the nominated occupation; and
(ii)      the person is a party to a work agreement;
the name of the occupation and the corresponding 6-digit code (if any) as they are specified in the work agreement;
(d)the location or locations at which the nominated occupation is to be carried out.
(8B)The Minister is satisfied that the person has, in writing, certified as part of the nomination whether or not the person has engaged in conduct, in relation to the nomination, that constitutes a contravention of subsection 245AR(1) of the Act.;
(9)The Minister is satisfied that either:
(a)there is no adverse information known to Immigration about the person or a person associated with the person; or
(b)it is reasonable to disregard any adverse information known to Immigration about the person or a person associated with the person.
(10)If the person is a standard business sponsor — the Minister is satisfied that:
(a)if the nomination was made before 1 July 2010 - the nominated occupation corresponds to an occupation specified by the Minister in an instrument in writing for this paragraph; and
(aa)if the nomination is made on or after 1 July 2010 – the nominated occupation and its corresponding 6-digit code correspond to an occupation and its corresponding 6-digit code specified by the Minister in an instrument in writing for this paragraph and the occupation is applicable to the person identified in the nomination in accordance with the specification of the occupation; and
(b)if required by the instrument mentioned in paragraph (a) or (aa) — the nomination of an occupation mentioned in the instrument is supported, in writing to the Minister, by an organisation specified by the Minister in an instrument in writing for this paragraph; and
(c)the terms and conditions of employment of the person identified in the nomination will be no less favourable than the terms and conditions (including, if applicable, the terms and conditions provided by an enterprise agreement under the Fair Work Act 2009) that are provided or would be provided to an Australian citizen or an Australian permanent resident for performing equivalent work at the same location; and
(cc)the base rate of pay, under the terms and conditions of employment mentioned in paragraph (c), that:
(i)       are provided; or
(ii)      would be provided;
to an Australian citizen or an Australian permanent resident, will be greater than the temporary skilled migration income threshold specified by the Minister in an instrument in writing for this paragraph; and
(d)if the nomination was made before 1 July 2010 - the person has certified as part of the nomination, in writing, that:
(i)       the tasks of the position include a significant majority of the tasks of:
(A)the nominated occupation listed in the ASCO; or
(B)the nominated occupation specified in an instrument in writing for paragraph (a); and
(ii)      if the person is lawfully operating a business outside Australia but does not lawfully operate a business in Australia:
(A)the nominated occupation is a position in the business of the standard business sponsor; or
(B)the nominated occupation is an occupation specified by the Minister in an instrument in writing for this sub-paragraph; and
(iii)     if the person lawfully operates a business in Australia:
(A)the nominated occupation is a position with a business, or an associated entity, of the person; or
(B)the nominated occupation is an occupation specified by the Minister in an instrument in writing for this sub-paragraph; and
(iv)     the qualifications and experience of the visa holder, or the applicant or proposed applicant for the visa, identified in relation to the nominated occupation are commensurate with the qualifications and experience specified:
(A)for the occupation in the ASCO; or
(B)if there is no ASCO code for the nominated occupation — for the occupation in the instrument in writing made for the purpose of paragraph (a); and
(e)if the nomination is made on or after 1 July 2010 – the person has certified as part of the nomination, in writing, that:
(i)       the tasks of the position include a significant majority of the tasks of:
(A)the nominated occupation listed in the ANZSCO; or
(B)the nominated occupation specified in an instrument in writing for paragraph (aa); and
(ii)      if the person is lawfully operating a business outside Australia but does not lawfully operate a business in Australia:
(A)the nominated occupation is a position in the business of the standard business sponsor; or
(B)the nominated occupation is an occupation specified by the Minister in an instrument in writing for this sub-subparagraph; and
(iii)     if the person lawfully operates a business in Australia:
(A)the nominated occupation is a position with a business, or an associated entity, of the person; or
(B)the nominated occupation is an occupation specified by the Minister in an instrument in writing for this sub-subparagraph; and
(iv)     the qualifications and experience of the visa holder, or the applicant or proposed applicant for the visa, identified in relation to the nominated occupation are commensurate with the qualifications and experience specified:
(A)for the occupation in the ANZSCO; or
(B)if there is no ANZSCO code for the nominated occupation - for the occupation in the instrument in writing made for paragraph (aa).
(f)the position associated with the nominated occupation is genuine; and
(g)if the person has identified in the nomination the holder of a Subclass 457 (Temporary Work (Skilled)) visa in relation to whom the requirements in subclause 457.223(6) of Schedule 2 were met—one of the following applies:
(i)       the requirements in subclause 457.223(6) of Schedule 2 continue to be met;
(ii)      if:
(A)the holder would be required to hold a licence, registration or membership that is mandatory to perform the occupation nominated in relation to the holder; and
(B)in order to obtain the licence, registration or membership, the holder would need to demonstrate that the holder has undertaken a language test specified by the Minister under subparagraph 457.223(4)(eb)(iv) of Schedule 2 and achieved a score that is better than the score specified for the test by the Minister under subparagraph 457.223(4)(eb)(v) of Schedule 2;
the holder demonstrates that he or she has proficiency in English of at least the standard required for the grant (however described) of the licence, registration or membership;
(iii)     the holder is an exempt applicant within the meaning of subclause 457.223(4) of Schedule 2;
(iv)     unless subparagraph (ii) applies—the holder:
(A)has undertaken a language test specified by the Minister under subparagraph 457.223(4)(eb)(iv) of Schedule 2; and
(B)achieved within the period specified by the Minister in a legislative instrument for this subparagraph, in a single attempt at the test, the score specified by the Minister under subparagraph 457.223(4)(eb)(v) of Schedule 2; and
(h)either:
(i)       the person will:
(A)engage the visa holder, the applicant for a visa or the proposed applicant for a Subclass 457(Temporary Work (Skilled)) visa only as an employee under a written contract of employment; and
(B)give a copy of that contract to the Minister; or
(ii)      the nominated occupation is an occupation specified by the Minister in an instrument in writing for sub-subparagraph (e)(iii)(B).
(10AA)For paragraphs (10) (c) and (cc), if no Australian citizen or Australian permanent resident performs equivalent work in the person’s workplace at the same location, the person must determine, using the method specified by the Minister in an instrument in writing for this subregulation:
(a)the terms and conditions of employment; and
(b)the base rate of pay, under the terms and conditions of employment;
that would be provided to an Australian citizen or an Australian permanent resident to perform equivalent work in the person’s workplace at the same location.
(10AB)Paragraphs (10) (c) and (cc) do not apply if the annual earnings of the person identified in the nomination are equal to or greater than the amount specified by the Minister in an instrument in writing for this subregulation.
(10A)The Minister may disregard the criterion in paragraph (10) (cc) for the purpose of subregulation (2) if:
(a)the base rate of pay will not be greater than the temporary skilled migration income threshold specified for that paragraph; and
(b)the annual earnings are equal to or greater than the temporary skilled migration income threshold; and
(c)the Minister considers it reasonable to do so.
(11)If the person is a party to a work agreement (other than a Minister) — the Minister is satisfied that:
(a)the nominated occupation is specified in the work agreement as an occupation that the person may nominate; and
(b)if the nomination was made before 1 July 2010 - the person has certified as part of the nomination, in writing, that:
(i)       the tasks of the position include a significant majority of the tasks of:
(A)if the nomination is made using an ASCO code - the nominated occupation listed in the ASCO; or
(B)if the nomination is not made using an ASCO code -the nominated occupation specified in the work agreement; and
(ii)      the qualifications and experience of the visa holder, or the applicant or proposed applicant for the visa, identified in relation to the nominated occupation are commensurate with the qualifications and experience specified for the occupation in the work agreement; and
(c)if the nomination is made on or after 1 July 2010 - the person has certified as part of the nomination, in writing, that:
(i)       the tasks of the position include a significant majority of the tasks of:
(A)if the nomination is made using an ANZSCO code - the nominated occupation listed in the ANZSCO; or
(B)if the nomination is not made using an ANZSCO code -the nominated occupation specified in the work agreement; and
(ii)      the qualifications and experience of the visa holder, or the applicant or proposed applicant for the visa, identified in relation to the nominated occupation are commensurate with the qualifications and experience specified for the occupation in the work agreement.
(12)If the person is a party to a work agreement and the work agreement specifies requirements that must be met by the party to the work agreement — the Minister is satisfied that the requirements of the work agreement have been met.

[2019] AATA 2806

30 May 2019

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Statutory Construction

Jurisdiction