BHA16 v Minister for Immigration
[2020] FCCA 238
•12 February 2020
FEDERAL CIRCUIT COURT OF AUSTRALIA
| BHA16 v MINISTER FOR IMMIGRATION & ANOR | [2020] FCCA 238 |
| Catchwords: MIGRATION – Protection visa application – extension of time – where acceptable explanation for delay is provided – where no relevant prejudice – where grounds of review unparticularised – not necessary in the interests of the administration of justice to extend time – application dismissed. |
| Legislation: Judiciary Act 1903 (Cth), s.39B |
| Cases cited: AYI16 vMinister for Immigration and Border Protection [2017] FCA 1358 |
| Applicant: | BHA16 |
| First Respondent: | MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS |
| Second Respondent: | ADMINISTRATIVE APPEALS TRIBUNAL |
| File Number: | MLG 1111 of 2016 |
| Judgment of: | Judge A Kelly |
| Hearing date: | 4 February 2020 |
| Date of Last Submission: | 4 February 2020 |
| Delivered at: | Melbourne |
| Delivered on: | 12 February 2020 |
REPRESENTATION
| The Applicant: | In Person |
| Counsel for the Respondents: | Mr C.E.A. Hibbard |
| Solicitors for the Respondents: | Clayton Utz |
ORDERS
The application for an extension of time within which to commence this proceeding be dismissed.
The applicant pay the costs of the first respondent fixed at $6,000.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT MELBOURNE |
MLG 1111 of 2016
| BHA16 |
Applicant
And
| MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS |
First Respondent
| ADMINISTRATIVE APPEALS TRIBUNAL |
Second Respondent
REASONS FOR JUDGMENT
Introduction
By application dated 26 May 2016, the applicant seeks judicial review of a decision of the Administrative Appeal Tribunal (Tribunal) made on 8 April 2016 affirming a decision of a delegate of the first respondent (Minister) refusing to grant him a Protection visa (visa) pursuant to s 65 of the Migration Act 1958 (Act).
By his application, the applicant sought an extension of time pursuant to s.477 of the Act within which to seek judicial review of that decision.
For the reasons which follow I have concluded that the application should be dismissed. In summary, I have concluded that the Tribunal properly considered each of the applicant’s objections to relocation. In that context, I do not consider that the applicant has raised a proposed ground of review that is sufficiently arguable or has reasonable prospects of success. Further, I discern no other arguable ground on the materials comprising the court book, including the Tribunal’s reasons.
The applicant is a male Pakistani citizen of Pashtun ethnicity and Sunni Muslim religion aged 29 years who first arrived in Australia (via Malaysia and then Indonesia) at Christmas Island on 5 August 2012 as an irregular maritime arrival.
When applying for the visa, the applicant supplied a number of documents, including a statutory declaration dated 4 December 2012 in which he stated that:
a)he had been raised in Boshehre village, Parachinar, where he attended Kohsar Public School until he was aged 17 years and thereafter attended the Oxford Public School in Sadda;
b)in 2008, the Taliban came to Parachinar and threatened teachers. Some teachers who did not stop teaching were killed. Due to the lack of teachers, Oxford Public School was closed down, which meant that he was forced to study at an Islamic college in Peshawar;
c)the Vice Chancellor of the Islamic college (who had allowed girls to attend the school) was later kidnapped by the Taliban and has not been seen again;
d)in 2010, one night on the way back to Peshawar after visiting his family, he was shot at by unknown persons;
e)Shia terrorists had placed a large amount of landmines around his village which have killed a number of people, including his cousin;
f)in March 2012, he refused a request by the Taliban that he, or a member of his family, become part of that organisation. He said that as his refusal placed his life at great risk, he fled to Australia.
Delegate’s decision
On 8 January 2014, a delegate of the Minister made a decision to refuse to grant the visa. The delegate did not accept as genuine the applicant’s claim that the Taliban wanted him or a member of his family to join it, or that his refusal to do so placed his life at great risk. The delegate was also not satisfied that the applicant remained at a greater risk of harm from Shia militia groups as compared to any other Pashtun Sunnis living in his area. The delegate found that the applicant did not have a well-founded fear of persecution for any reason, and concluded that the applicant was not a person in respect of whom Australia owed protection obligations, either as a refugee under s 36(2)(a) or by way of complementary protection under s 36(2)(aa) of the Act.
Tribunal’s decisions
On 15 January 2014, the then Refugee Review Tribunal received an application from the applicant for review of the delegate’s decision.
The matter then proceeded before a Tribunal on two occasions.
On 27 April 2015, the applicant’s representative filed submissions and on 4 May 2015, he attended a Tribunal hearing and was assisted by his representative and a Pashto interpreter.
On 20 May 2015, the Tribunal affirmed the delegate’s decision. This Tribunal did not accept that the levels of Convention-related or non-Convention related or generalised violence in Islamabad or Rawalpindi made relocation within Pakistan for the applicant unreasonable.[1]
[1] Reasons of RRT dated 20 May 2015, [37].
Following an application to this court for judicial review of the Tribunal’s decision, on 4 December 2015, orders were made, by consent, remitting the application for reconsideration. Relevantly, the Minister conceded that the Tribunal’s decision was affected by jurisdictional error because it failed to consider the applicant’s circumstances in assessing the reasonableness of relocation within Pakistan.
Following an invitation to attend a hearing to give evidence and present arguments relating to the issues arising on the decision under review, on 5 April 2016, the applicant attended that hearing, doing so with the aid of a Pashto interpreter.
On 8 April 2016, the Tribunal made a decision affirming the delegate’s decision to refuse to grant the applicant a Protection visa. The Tribunal provided a statement of its reasons for doing so (Reasons).
The Tribunal provided a brief background of the application at [1]-[4] and identified the relevant law regarding the refugee criterion and the complementary protection criterion, in each case addressing issues respecting both state protection and relocation: [5]-[23].
The Tribunal then summarised the applicant’s claims at [25]-[29]. In making its findings and conclusions upon those claims, the Tribunal:
a)found that the applicant had given consistent and credible evidence which accorded with country information: [31];
b)accepted his claims regarding the Taliban having threatened teachers, his school being shut down, and his being forced to travel to Peshawar in order to study. It also accepted that he had been shot at on the way to Peshawar and that Shia terrorist groups had placed landmines around his village: [32]-[34];
c)recorded country information indicating a substantial improvement to security in his home area and noted he had told the Tribunal that his family would not tell him if anything had happened to them so as not to upset him: [35]-[37];
d)researched the applicant’s claim that he could not study computer science in Parachinar because the college had been closed but had been unable to verify whether it was correct: [38];
e)found that there were strong indicators suggesting that his chances of facing serious harm and significant harm in his home area were now remote (although there was still some level of militant activity there). It adopted a cautious approach when assessing his risk of harm and found that there were substantial grounds for believing there was a real risk the applicant may suffer significant harm, such risk being localised within his home area only: [38]-[39];
f)considered country information and his individual circumstances to find that there were not substantial grounds for there being a real risk that he would suffer significant harm on the basis of being a forced to return to Pakistan as a failed asylum seeker: [43]-[47].
In addressing the question of relocation, the Tribunal considered in some detail whether it would be reasonable for him to relocate in Pakistan outside of his home area: [48]-[61]. In doing so, the Tribunal:
a)had regard to the applicant’s country information regarding the security situation in Pakistan, but gave greater weight to the DFAT reports which commented that there were viable relocation options. It did so because it considered the information was authoritative and more recent and that DFAT had “been charged with the provision of advice to the Australian government”: [49];
b)considered country information which did not indicate that Sunnis faced either a real chance of persecution or a real risk of harm in Punjab (including Lahore), or Islamabad/Rawalpindi: [53];
c)considered his individual circumstances, including that he would have no family connections in Punjab or Islamabad/Rawalpindi, but relied upon DFAT country information to find that this would not mean that the chance or risk of being seriously harmed or significantly harmed would be more than remote: [54];
d)observed that in its consideration of whether it would be reasonable for him to relocate to Lahore and Islamabad/Rawalpindi, it had taken into account factors such as his level of education, his ability to obtain work and accommodation, and his ability to work and live away from his family whilst in Australia: [57];
e)accepted that there were anecdotal reports of Pashtun migrants in Lahore experiencing a level of harassment and having difficulty obtaining identity cards, but that these reports did not make it unreasonable for him to relocate there: [58];
f)considered the low criminality rate in urban areas of Pakistan was not at a level to make it unreasonable for him to relocate: [59].
Having considered all of his individual circumstances and the available country information, it found that it would be reasonable for him to relocate outside of his home area to Lahore and Islamabad/Rawalpindi to avoid the localised threat of serious harm that he faced: [60]-[61].
The Tribunal concluded that the applicant was not a person to whom Australia owed protection obligations, and affirmed the decision to refuse to grant the visa: [62]-[65].
Procedural history
On 26 May 2016, the applicant filed an application for judicial review of the Tribunal’s decision. By two affidavits filed with that application, the applicant exhibited a copy of the Reasons and provided an explanation of why he had not filed his application within the 35 day time limit fixed by the Act.
By a Response filed on 4 July 2016, the Minister opposed the making of the orders sought in the application on the grounds that the application did not establish any jurisdictional error in the decision of the Tribunal. The application for an extension of time was opposed.
On 2 October 2016, orders were made, by consent, listing the matter for final hearing. Orders were made affording the applicant opportunities to file any amended application, affidavits and submissions, however, those opportunities were not taken.
On 24 January 2020, the Minister filed written submissions. As the applicant had not filed any further affidavits or submissions, the Minister’s submissions were responsive to the grounds in the application.
Applicable principles
By s 477(1), a 35-day time limit is fixed for the making of an application for judicial review of a migration decision. The court may extend the time for filing an application: s 477(2).
The power to extend time is subject to two conditions: (1) an application has been made in writing for such an extension, in which the applicant specifies why it is necessary in the interests of administration of justice for an extension to be granted; (2) the court is satisfied that it is necessary in the interests of administration of justice to do so.[2]
[2]For the avoidance of doubt, the 35 day time limit commences from the date of the migration decision, irrespective of the validity of the decision: see s 477(3)-(5).
The discretion to extend time for the commencement of proceedings is a deliberately broad one.[3] It is well-settled that in the determination of whether an extension of time should be granted, the court should consider a number of factors including whether there is an acceptable explanation for the delay, the length of the delay, any prejudice to the respondent if the extension was granted, the merits of the substantive application and any other factor considered to be relevant.[4]
[3]Mohammad v Minister for Immigration and Border Protection [2014] FCA 1249, [25].
[4]Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344, 348-9; SZMFT v Minister for Immigration and Citizenship [2008] FCA 1725, [21]; SZNFR v Minister for Immigration and Citizenship [2009] FCA 851, [12]; SZSPR v Minister for Immigration and Border Protection (2013) 139 ALD 109, [16]; MZZQA v Minister for Immigration and Border Protection [2016] FCA 584, [8]; CTY15 v Minister for Immigration and Border Protection [2017] FCA 1354, [4]; AYI16 vMinister for Immigration and Border Protection [2017] FCA 1358, [10]-[11].
While the discretion is broad, the court should not grant an application for an extension of time unless it is proper to do so. That this is so brings to attention that legislative time limits are not to be ignored.[5] Equally, the discretion conferred recognises that there will be cases in which, although no prejudice may be sustained by the Minister, the consequences for an applicant in losing a right of review are real.
[5] Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344, 348.
The applicant was self-represented before me and assisted by an interpreter. As he was self-represented, I have re-examined the materials comprising the court book, the Tribunal’s reasons and application for review.
Length of delay & explanation.
On the face of the Reasons, the Tribunal’s written statement was made on 8 April 2016 at 6:30pm. In those circumstances, the applicant properly concedes that the application was made ~12 days out of time.
By his second affidavit, the applicant explained that, having finalised his application with the assistance of the Asylum Seeker Resource Centre late on 11 May 2016, he intended to lodge the application the following day. Had he done so, the application would have been lodged in time. However, the applicant deposed that he became sick and did not attend court until 19 May 2016, on which date he was informed by the registry that the application was out of time. Having obtained further legal assistance to prepare his second affidavit, the applicant then lodged his documents on 25 May 2016.
Counsel for the Minister properly accepted there had been minimal delay and that an explanation had been provided.
Prejudice
While the Minister accepted that he would not suffer any prejudice in responding to the application if the court were to grant an extension of time, the absence of prejudice is not of itself sufficient or capable of supporting a conclusion that it is necessary and in the interests of the administration of justice to grant an extension.[6]
[6]Hunter Valley Developments Pty Ltd v Cohen (1984) 3 FCR 344, 349; SZSQL v Minister for
Immigration and Border Protection [2015] FCA 294, [15]; SZTRY v Minister for Immigration and Border Protection [2015] FCAFC 86, [6] (The Court).
Contrastingly, it should be recognised that the question of prejudice falls for consideration in the context that by s.476A(3)(b) of the Act, no appeal lies from an order of this court either granting or refusing an application for an extension of time under s.477(2).[7]
[7]However, it appears that an alternative route may be open via s 39B of the Judiciary Act 1903 (Cth): AZAFJ v Minister for Immigration and Border Protection, [2016] FCA 291 [3]-[4] and cases cited (Bromwich J).
Merits of proposed application
The Minister opposed the application on the substantive basis that there was insufficient merit in the proposed grounds of review to warrant an extension of time. Expressed in positive terms, if the court concluded that there was no sufficiently arguable merit to the substantive application, it will not be necessary in the interests of the administration of justice to exercise the power to grant an extension of time.
Consideration of whether it is necessary in the interests of the administration of justice to grant the extension thus requires an evaluation of the merits of the proposed application. In the present case, I am not satisfied that the proposed grounds of review are of sufficient merit as to warrant the grant of an extension of time.
The application raised two grounds of review, contending that the Tribunal’s decision: (1) “is affected by an error of law; and” (2) “denied the applicant procedural fairness.” Each of those grounds was devoid of particulars and want to be rejected on that basis alone.
As the authorities confirm, if an extension of time is to be granted, the court must be satisfied that it is in the interests of justice to do so.[8] Whether an extension of time should be granted will depend upon the particular circumstances of each case.[9]
[8]SZSZW v Minister for Immigration and Border Protection[2018] FCAFC 82, [27] (Collier, Wigney and Gleeson JJ); MZABP v Minister for Immigration and Border Protection[2016] FCAFC 110, [38] (Tracey, Perry and Charlesworth JJ).
[9]Mentink v Minister for Home Affairs [2013] FCAFC 113, [32]-[38] (Edmunds, Griffiths, Pagone JJ).
In MZABP v Minister for Immigration and Border Protection, the Full Court endorsed statements by Mortimer J in the decision under appeal, that the approach to be taken to a preliminary examination of the merits of the substantive application necessarily involved recognition that the grounds had not been as fully considered, developed and argued as if on a final hearing and, accordingly, that it was not a function appropriate to the exercise of discretion to grant an extension of time to undertake a fuller consideration of the merits of the substantive claim. Mortimer J’s reasoning is instructive:[10]
. . . it will seldom be in the interests of the administration of justice to grant leave where an appeal has little or no prospects of success, because of the resources expended by the parties and the Court, and the inevitable impact on other litigants who have abided by time limits and are waiting for their appeals to be heard, in circumstances where an unsuccessful outcome can be confidently predicted at the leave stage. There is, however, in that approach a level of certainty about the unsuccessful outcome which is not borne of an exhaustive preliminary examination of the grounds as if they had been fully considered, developed and argued. Rather, the certainty or confidence a judge may have about an unsuccessful outcome is because the grounds on their face, and without the detailed argument and development which attends a full hearing, are plainly hopeless.... If a judge travels beyond an examination of the grounds at what should be a reasonably impressionistic level (see . . . Jackamarra v Krakouer[11]) into a fuller consideration of the arguments for and against each ground of review, then in my respectful opinion that is not a function appropriate to a discretion such as that contained in s 477(2).
The correct approach may be expressed by the use of language such as whether a ground is “arguable”, “reasonably arguable”, “sufficiently arguable” or has “reasonable prospects of success” . . .
The Full Court’s endorsement of her Honour’s use of the criterion ‘reasonable prospects of success’ is apparent. It is akin to that employed in an application for summary judgment where the court is authorised to dismiss a claim or defence where it is considered to have no reasonable prospects of success.[12] It is a criterion which is long accepted as posing a lower threshold than that which is applied on the final determination of the issues in a proceeding. It follows that if the other requirements for an extension of time are satisfied, the time within which to lodge an application for judicial review should be extended if the proposed grounds of review are shown to be reasonably or sufficiently arguable.
[10][2015] FCA 1391, [62]-[63].
[11](1998) 195 CLR 516, [7]-[9].
[12] cfSpencer v Commonwealth (2010) 241 CLR 118.
The trend of authority favours an approach to the determination of whether it is necessary in the interests of the administration of justice to grant an extension of time that the merits of the application should be evaluated at a reasonably impressionistic level such that the court is satisfied to a degree of confidence whether the grounds of review are arguable, reasonably arguable, sufficiently arguable or plainly hopeless. Further, in the consideration of whether the grounds of an application are sufficiently arguable, the court is not confined to a consideration of the proposed grounds of review but must also engage with the reasons of the Tribunal to consider whether the grounds are of any substance: see SZSZW v Minister for Immigration and Border Protection at first instance[13] and on appeal;[14] Kio v Minister for Home Affairs.[15] Those authorities confirm that the discretion is deliberately broad.
[13][2017] FCA 1544, [14]-[17] (Perry J) citing MZABP; DMI16 v Minister for Immigration and Border Protection [2017] FCA 1179, [33]-[36] (Robertson J).
[14] [2018] FCAFC 82, [26]-[27] (The Court).
[15] [2019] FCA 579, [4], [10].
Resolution
As noted above, despite the opportunity which was extended to the applicant to file a further affidavit and submissions, he did not do so. However, before me, the applicant sought to rely upon a series of documents which, he said, demonstrated the nature of the risk which he faced if he was to return to Pakistan. None of those documents had been served upon the respondents.
The documents were supplied to counsel for the Minister in order that, as model litigant, some consideration could be given to them and submissions made as to their relevance and admissibility. Counsel submitted that all of the documents appeared to have been created in 2018 and to be relied upon in a merits review of the application.
The documents were supplied to the court so as to evaluate that objection. The bundle comprised 9 documents bearing various dates between July – September 2018 and were for the most part typed in English. As the applicant submitted, the documents comprised medical records relating to treatment which had been administered to his mother following injuries she had received following a bomb blast. Of most immediate relevance was a clinical record of The Lady Reading Hospital, Pershawar, dated 10 July 2018 which recorded the patient’s admission (on 10 July) and discharge (on 11 August) with a diagnosis of “bomb blast injury” and the treatment which had been provided to a middle-aged female. The patient had been treated for multiple injuries to the back of her chest and admitted for observation until 11 August 2018.
The documents post-date the Tribunal’s decision made on 8 April 2016. I accept the submission on behalf of the Minister that the documents go to the merits of the applicant’s claim to fear harm in his home region. More fundamentally, however, the documents are of no relevance because the Tribunal accepted at [39] that there was a real chance the applicant, both now and in the reasonably foreseeable future, would face serious harm in his home region and may suffer significant harm in that area. As the Tribunal accepted the risk of harm, the documents were not relevant as the issue had been decided in his favour.
The applicant was asked to identify why the decision was affected by serious error. He submitted that internal relocation was not reasonable for several reasons. First, he said that he could not survive financially. Secondly, he said that he was from a tribal area and would be discriminated against wherever he relocated to. Thirdly, he said that he faced a risk of harm wherever he went to.
The Tribunal’s treatment of the question of relocation is to be assessed in light of the framework of the applicant’s objections to relocation. In the present case, submissions were filed on two occasions on the applicant’s behalf. First, on 27 April 2015, the applicant’s lawyers filed submissions before the RRT (which first considered the application) and which addressed the question of “internal flight or relocation alternative” at [27]-[32]. Those submissions directed attention, amongst other things, to the terms of the UNHRC’s Guidelines on the subject and noted that the applicant did not have any relatives or friends who could assist him. Secondly, on 11 May 2015, a further set of submissions was filed by those lawyers which again addressed the relevance of relocation at [8]-[11] and the reasonableness of relocation at [12]-[17]. These post-hearing submissions were also addressed to the RRT and both reiterated and addressed in further detail the nature of the applicant’s objections to relocation. While no further submissions were filed before the Tribunal on remittal, each of the foregoing submissions was before it when its decision (the subject of the present review) was made.
The Tribunal addressed the question of relocation in detail: [22]-[23], [48]-[61]. The applicable legal principles and guidelines were identified.
In particular, the Tribunal expressly addressed the UNHCR guidelines when considering whether it would be reasonable for the applicant to relocate: [57]. In doing so, it took into account that the applicant had no relatives, friends or tribal members who could assist and, by reference to DFAT country information, accepted that the loss of family connections could make relocation difficult. By contrast, the Tribunal also took into account that the applicant (then aged 24 years), had no family of his own to support and did not claim to have any health problems. It also noted that he had completed his education to year 12 in Pakistan and been able to obtain employment in Australia, thereby demonstrating an ability to live away from his family for an extended period of time. The Tribunal also referred to DFAT country information commenting on the high levels of internal migration in Pakistan and that large urban centres offered better opportunities for employment than those which were smaller. It also noted that, in both Lahore and Islamabad/Rawalpindi, there were large Pashtun populations and that country information indicated persons of Pashtun ethnicity were doing very well in business “as evidenced by the fact that 70% of businesses in Lahore are owned by Pashtun migrants.” It also noted that there was no evidence to indicate accommodation shortages or that the applicant would be denied access to government services, including that healthcare was generally free and accessible to all Pakistanis. In addition, the Tribunal took into account that the applicant could read and write (in both English and Urdu) which would assist him to integrate and find work. The Tribunal found that the applicant would be able to obtain work, education and accommodation: [57].
Equally, the Tribunal had regard to country information and the UNHCR guidelines addressing the question of harassment and violence, finding that neither of those factors were such as to make it unreasonable for the applicant to relocate: [58]-[60].
Having regard to each of the applicant’s stated objections to relocation and the consideration which was given to them, including country information and his individual circumstances, the Tribunal concluded that it would be reasonable for the applicant to relocate outside of his home area to Lahore and Islamabad/Rawalpindi: [61].
I cannot see any reasonably or sufficiently arguable basis for the applicant’s complaint that the decision is affected by an error of law.
Insofar as the applicant complains of a denial of procedural fairness, that is to be considered in the statutory context in which the application fell for consideration on review by the Tribunal.
The review of the visa application fell for review under Pt 7 of the Act. Division 4 of Pt 7 provides a statutory regime of procedural fairness. Section 422B states that Division 4 of Part 7 is “an exhaustive statement of the requirements of the natural justice hearing rule in relation to the matters it deals with”. As noted, the complaint of denial of procedural fairness was not illuminated by any particulars.
In my view, there is no basis to suggest that the Tribunal did not comply with its obligation to provide procedural fairness to the applicant. It complied with s 425 when it invited the applicant to attend a hearing before it by letter dated 7 April 2015. The applicant attended the hearing on 4 May 2015. After the matter was remitted to the Tribunal, it invited the applicant to a further hearing, which took place on 5 April 2016. The applicant was afforded opportunities to give evidence and present arguments on the issues arising on the decision under review.
The applicant was sufficiently on notice of the “issues arising in relation to the decision under review” to have commented on those issues at the hearing, not least because those issues also formed the basis of the first Tribunal decision. The Tribunal otherwise relied on information in accordance with s 424A of the Act.
In my view, it is not reasonably arguable that the applicant was denied procedural fairness.
Conclusion
The Tribunal conducted its review in accordance with Pt 7 of the Act and properly addressed each of the applicant’s objections to relocation. Adopting the lower threshold that is to be applied upon an application for an extension of time, I do not accept that either of the applicant’s grounds of review have reasonable prospects of success.
The determination of whether it is necessary in the interests of the administration of justice to grant an extension of time requires that the delay, explanation for delay, prejudice, the relative merits of the proposed grounds and the other matters that I have considered above be considered both individually and cumulatively. For the reasons above, I am not satisfied that it is necessary in the interests of the administration of justice to grant the application for an extension of time in which to apply for judicial review. Nor, in my opinion, would it otherwise be appropriate in the exercise of discretion to do so.
I certify that the preceding fifty-six (56) paragraphs are a true copy of the reasons for judgment of Judge A Kelly
Associate:
Date: 12 February 2020
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