Bit19 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs

Case

[2021] FCCA 619

31 March 2021


FEDERAL CIRCUIT COURT OF AUSTRALIA

BIT19 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 619

File number(s): ADG 114 of 2019
Judgment of: JUDGE EGAN
Date of judgment: 31 March 2021
Catchwords: MIGRATION – application for Safe Haven Enterprise Visas – fast-track review process – evidence presented in a way to advance prospects of success of migration application – no illogicality or irrationality demonstrated – no jurisdictional error established – application dismissed.
Legislation: Migration Act 1958 (Cth), ss 5H, 5J, 36(2)(a), 36(2)(aa) 473CB.
Cases cited:  Minister for Immigration and Citizenship v SZMDS (2010) 240 CLR 611.
SZUXN v Minister for Immigration and Border Protection (2016) 69 AAR 210.
Minister for Immigration and Citizenship v Li (2013) 249 CLR 332.
Number of paragraphs: 27
Date of last submission/s: 25 March 2021
Date of hearing: 25 March 2021
Place: Brisbane
Counsel for the Applicants: Mr Kummerow
Solicitor for the Applicants: Cares Lawyers
Solicitor for the First Respondent: Mr Cummings of Sparke Helmore
Second Respondent: Submitting appearance save as to costs

ORDERS

ADG 114 of 2019
BETWEEN:

BIT19

First Applicant

BIU19

Second Applicant

BIV19 (and another named in the Schedule)

Third Applicant

AND:

MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS

First Respondent

IMMIGRATION ASSESSMENT AUTHORITY

Second Respondent

ORDER MADE BY:

JUDGE EGAN

DATE OF ORDER:

31 MARCH 2021

IT IS ORDERED THAT:

1.The Originating Application for Review filed on 1 April 2019 be dismissed.

2.The First Applicant and the Second Applicant pay the First Respondent’s costs of and incidental to the Application for Review, fixed in the amount of $5,000.

REASONS FOR JUDGMENT

JUDGE EGAN:

  1. The applicants are citizens of Vietnam. The first and second applicants arrived at Christmas Island by boat as unauthorised maritime arrivals in July 2013. The third and fourth applicants were children of the first and second applicants who were respectively born in Australia in 2015 and 2017.

  2. On 20 December 2016, the first and second applicants made application for Safe Haven Enterprise Visas (SHEV). The third and fourth applicants are secondary applicants and they did not raise any claims of their own.

  3. On 20 November 2018, the applicants attended an interview with a delegate of the Minister. On 10 January 2019, the delegate refused to grant the SHEV applications. On 18 February 2019, the applicants provided a submission to the Immigration Assessment Authority (‘the Authority’) that did not contain any new information. On 26 February 2019, the Authority affirmed the delegate’s decision to refuse to grant the visas.     

  4. At [3] of its reasons, the Authority recorded that it had had regard to the material provided to it by the Secretary pursuant to the provisions of s. 473CB of the Migration Act 1958 (Cth) (‘the Act’).

  5. At [6] of the reasons of the Authority, the first applicant’s claims were summarised as follows:

    •“He is a Vietnamese citizen, of Kinh ethnicity and Catholic religion, from Binh Thuan Province of Vietnam, and worked in his family fishing business.

    •There was an incident in March 2013 whilst out fishing in Vietnamese waters and a Chinese boat hit their boat and sprayed them with a powerful jet of water. The front of the boat was damaged. They drove the boat to the closest island and reported the incident to Vietnamese water police, however the police hit him and said they could not help. He was locked up on the boat for one day, along with the other crew members. The police told them not to say anything about the Chinese to other fishermen. On return to the mainland he told people about what had happened, and told other fishermen so they would not go there and get into trouble.

    •A few days later the sea police took him to the police station inland and hit him again. They did not like him talking about the Chinese to the other fishermen. Every two to three days the police would call him to come to the police station where they would hit him and tell him off for telling the other fishermen. They told him not to stay in the village anymore.

    •His whole family were very scared and they sat together and made the decision to leave Vietnam, as once you have trouble with police in Vietnam you cannot live peacefully.

    •Whilst in immigration detention, in Wickham Point Darwin, the Australian government gave his personal details to the Vietnamese police who came to the camp.

    •He will be imprisoned on return to Vietnam because he left illegally, and because he was one of the organisers of the trip to Australia, along with his brother-in-law.

    •He will be jailed on return to Vietnam because his name is on a list of people who say bad things about the government.

    •He is a leader of the International Youth Movement for Human Rights (IYMFHR) Queensland Chapter and has been involved in various protests, including against the Vietnamese government's failure to protect its citizens against the Chinese invasion, the sale of Vietnamese land to China, Chinese companies polluting Vietnamese waters, and about the imprisonment by Vietnamese authorities of people who fight for human rights.

    •The Vietnamese government would be aware of his involvement in these activities because he has posted information on social media, including on YouTube. He fears he will be imprisoned for 20 years or more on return to Vietnam because of his role organising protests.

    •In 2014 his information was disclosed on the Department's website, and this is the reason Vietnamese authorities keep coming to his family home and hassling them.”

  6. At [7] – [8] of the reasons of the Authority, the Authority correctly articulated what constituted a refugee under the provisions of s. 5H of the Act, as well as what constituted a well-founded fear of persecution under the provisions of s. 5J of the Act.

    Grounds for Review

  7. The Grounds for Review relied upon by the applicants at the hearing before the Court were as follows:

    Grounds of application

    1.        The second respondent's findings in relation to:

    1.1 the first applicant's activities with the International Youth Movement for Human Rights Foundation, and his degree of involvement; and

    1.2      the first applicant's sole purpose in engaging in those activities; and

    1.3whether the first applicant would engage in similar activities if he returned to Vietnam;

    was irrational or illogical, and not open on the material before the second respondent. The second respondent's findings were material to its ultimate decision in that:

    1.4it determined, for the purpose of assessing complementary protection, that the first applicant was only a “low-level participant” when the uncontroverted material before it stated otherwise;

    1.5it determined, for the purpose of assessing complementary protection, that the International Youth Movement for Human Rights Foundation was not "against the state" and to "overthrow the Vietnamese government", when that was the very raison d 'etre for the organisation

    1.6it determined that it was not satisfied for the purposes of subs. 5J(6) of the Migration Act 1958 (Cth) that the first applicant engaged in activities with the International Youth Movement for Human Rights Foundation otherwise than for the purpose of strengthening the first applicant's claims, and thereby disregarded the relevant conduct.”

  8. At [11] and [12] of its reasons, the Authority recorded both the first applicant’s account of a confrontation with Chinese fisherman, as well as what it considered to be inconsistencies and irregularities in the first applicant’s claims, as follows:

    [11] The first applicant's statement of claims refers to an incident with some Chinese boats when he was out fishing in March 2013. He claims they encountered 18-20 Chinese fishing boats and two Chinese sea police boats in Vietnamese waters, that those boats came towards them and hit their smaller wooden boat damaging the front of the boat, and spraying them with a powerful jet hose. The first applicant was the second in charge of the boat, and his brother in- law was the skipper. They drove their boat to the closest island, and he and his brother-in law reported the incident to Vietnamese Water Police, who hit them, said they could not help with the problem, locked them and the rest of the crew up on the boat for one day. The police told them not to say anything about the incident to other fishermen, and he thinks that was because the Vietnamese government knew they could not protect the Vietnamese fishermen so they covered up the fact that the Chinese were coming into Vietnamese waters. On return to the mainland he told people, including other fishermen, about the incident. A few days later the 'Sea Police' took him to a police station inland and hit him because they did not like him talking about the Chinese. Every two or three days police called him to come to the police station, where they would hit him and tell him off for telling the other fishermen. They told him not to stay in the village anymore. He decided to leave Vietnam after the incident.

    [12] During the Entry interview, conducted shortly after his arrival in Australia, on 28 July 2013, the first applicant said whilst working as a fisherman in Vietnamese waters he was arrested, or detained, on his boat for a few hours by Chinese people at sea, their ship hit his boat, and after being released by the Chinese people he went to report to Vietnamese authorities, who arrested him for one day and night, and that the authorities caused trouble for him. He said he left Vietnam because Vietnamese authorities did not protect him from being harassed by the Chinese people. The applicant's evidence during the SHEV interview was that he left Vietnam because the government and authorities, especially police in his area, tried to put him in prison, and threatened his freedom and safety. His evidence regarding the incident with the Chinese boats contains a number of inconsistencies, and aspects which I find implausible, as follows:

    •During the SHEV interview the first applicant said he saw about 10 or 20 Chinese ships, and 'when (he) approached them they got angry and damaged his boat, and that the Chinese vessel(s) chased them to their port, which is inconsistent with the Entry interview indicating he was arrested by the Chinese people at sea and detained for a few hours, and after being released by them he went to report the incident to Vietnamese authorities. In addition, the statement of claims does not refer to his boat being chased, but merely states that the Chinese boat(s) went towards them, which is inconsistent with evidence at the SHEV interview that the first applicant's boat approached the Chinese vessel(s). The statement of claims described one of the Chinese vessels hitting his boat, and to them being sprayed with water, however no mention was made of his boat being hit during the SHEV interview, but only that they were sprayed with water. Given the proximity of the Chinese vessels to the first applicant's boat being close enough to spray them with water, and his description of the Chinese vessels being three or four times the size of his wooden boat, I consider if they had been chased by the vessel they would have been easily caught, and I consider it implausible that they were chased, but not apprehended.

    •I find it highly significant that the first applicant did not mention in his statement of claims, or during the SHEV interview, the claim made at the Entry interview that he was detained by the Chinese authorities for a few hours, which leads me to believe that information is not credible. In making this finding I note I am aware of the caution that needs to be exercised when relying on what an applicant said or omitted to say at an Entry interview conducted shortly after arrival in Australia after a long and difficult journey. Having listened to the Entry interview, during which the first applicant provided cogent responses to the interviewer's questions posed through an interpreter, it is not apparent to me circumstances of the interview materially impacted on his evidence.

    •During the SHEV interview initially when asked what happened after his boat was damaged the first applicant said they went to the 'border guard station' on one of the islands to report the incident, but his brother-in-law was captured and kept overnight in the station and they hit him. However immediately after, when asked what happened to him and the rest of the crew, he said he and his brother-in-law went to the station, and the rest of the crew remained on the boat. He said he was interviewed at the station for 24 hours and then released, and told not to share the information about the incident with anyone or risk serious charges. This evidence is inconsistent with the statement of claims, indicating both he and his brother-in-law were hit and locked on the boat, rather than detained at the station.

  9. At [13] of its reasons, the Authority recorded that country information indicated that the Vietnamese government defended its sovereignty in the disputed areas of the South China Sea, and that fisherman were encouraged to keep going to those areas to confirm that they belonged to Vietnam. Such country information also promoted China as being the aggressor in relation to such conflicts. The Authority did not accept as plausible the claim that the Vietnamese government was trying to cover up an incident of the type describe by the first applicant. The Authority also found that the level of interest the first applicant claimed the Vietnamese authorities had in him for speaking up about a boating incident involving Chinese interests was implausible and disproportionate. Finding that the first applicant’s evidence contained significant inconsistencies and was otherwise generalised and unconvincing, the Authority did not accept that the first applicant had been involved in any incident with a Chinese vessel. Having so found, the Authority did not accept that the first applicant had been questioned or detained by Vietnamese water police or by local Vietnamese authorities, or that that was the reason why the first applicant left Vietnam. The Authority found that the first applicant was not of interest to Vietnamese authorities at the time that he departed Vietnam.

    Consideration of Grounds of Review

  10. The applicants’ claims relate to the manner in which the Authority dealt with the first applicant’s association with an organisation called the “International Youth Movement for Human Rights Foundation” (‘the Foundation’). It was asserted that the Authority’s findings were irrational or illogical, and not open on the material before the Authority. There is no merit to such claims.

  11. The first claim was that the Authority’s finding that the first applicant was only a ‘low-level’ participant was irrational or illogical, and not open on the material before it. At [16] – [20] of its reasons, when considering the first applicant’s claims about his being a leader of the Queensland Chapter of the Foundation, the Authority referred to such claims having been made at the SHEV interview. The Authority also referred to the fact that after the SHEV interview, the first applicant had provided a submission claiming that he had actively promoted the application of democratic principles for Vietnam and that, as a result, it could be considered by the Vietnamese government that he was seeking to overthrow the government, as well as undermining national unity, spreading propaganda against the State of Vietnam, and infringing upon the interests of the State, those all being crimes under Vietnam’s penal code. The submission contained hyper-links to documents and videos said to relate to the first applicant’s activities in Australia in 2018.

  12. The findings of the Authority were open to it. It closely considered all of the relevant evidence in the light of the applicants’ claims and weighed it up appropriately before arriving at its decision.

  13. At [39] and [40] of its reasons, the Authority relied upon country information which indicated that only prominent high-profile activists were targeted by the authorities in relation to any government criticism. When recording that the first applicant had failed to produce any evidence of his online political activity, the Authority at [41] of its reasons said as follows:

    [41] During the SHEV interview the first applicant suggested all the photographs he provided of the protests are available on social media, on the IYMFHR website, and on his Facebook page. There is no evidence before me that the first applicant's name, or any photograph of him appears on the IYMFHR website. The delegate requested the first applicant provide a link to his Facebook profile, along with any other links he wanted the delegate to look at. Other than the links referred to above the first applicant did not provide a link to his Facebook profile, or to any online content that had been directly posted by him. There is no information before me to support the first applicant has posted any political or anti-Vietnamese government information online, and I do not accept he has done so.

  14. At [42] of its reasons, the Authority referred to the video compilation which did not identify the first applicant by name, albeit that his photograph appeared in such video.

  15. The Authority’s assessment of the first applicant’s profile was that it was low level. The Authority was entitled to arrive at that perception upon a reasonable consideration of the evidence before it. The first applicant’s organisation of a winter camp retreat at Mt Tamborine in Queensland, and his appointment to a committee role, were acts which were not determinative of his having a high profile. The question as to whether the first applicant had any such profile was a matter for the Authority. The Authority did not err in finding that the first applicant had a low profile which would not bring him to the attention of the authorities. It was a matter about which reasonable minds might differ. It cannot be said that no other rational or logical decision maker could not have made the same decision as the Authority. As was said by Crennan and Bell JJ in Minister for Immigration and Citizenship v SZMDS (2010) 240 CLR 611 at [130], [131] and [135]:

    “[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.

    [131] What was involved here was an issue of jurisdictional fact upon which different minds might reach different conclusions. The complaint of illogicality or irrationality was said to lie in the process of reasoning. But, the test for illogicality or irrationality must be to ask whether logical or rational or reasonable minds might adopt different reasoning or might differ in any decision or finding to be made on evidence upon which the decision is based. If probative evidence can give rise to different processes of reasoning and if logical or rational or reasonable minds might differ in respect of the conclusions to be drawn from that evidence, a decision cannot be said by a reviewing court to be illogical or irrational or unreasonable, simply because one conclusion has been preferred to another possible conclusion.”

    [135] On the probative evidence before the Tribunal, a logical or rational decision maker could have come to the same conclusion as the Tribunal. Whilst there may be varieties of illogicality and irrationality, a decision will not be illogical or irrational if there is room for a logical or rational person to reach the same decision on the material before the decision maker. A decision might be said to be illogical or irrational if only one conclusion is open on the evidence, and the decision maker does not come to that conclusion, or if the decision to which the decision maker came was simply not open on the evidence or if there is no logical connection between the evidence and the inferences or conclusions drawn. None of these applied here. It could not be said that the reasons under consideration were unintelligible or that there was an absence of logical connection between the evidence as a whole and the reasons for the decision. Nor could it be said that there was no probative material which contradicted the first respondent’s claims. There was. The Tribunal did not believe the first respondent’s claim that he had engaged in the “practice of homosexuality” in the UAE and accordingly it was not satisfied that he feared persecution if he returned to Pakistan.”

  1. The applicant has not demonstrated ‘extreme’ illogicality or irrationality on the part of the Authority. In SZUXN v Minister for Immigration and Border Protection (2016) 69 AAR 210, when discussing whether jurisdictional error had been demonstrated where some factual findings had been made which were said to be either irrational or illogical, Wigney J, at [52] and [55], said:

    “[52] As Robertson J put it in Minister for Immigration and Citizenship v SZRKT (2013) 212 FCR 99 at [148], for a decision to be vitiated for jurisdictional error based on illogical or irrational findings of fact or reasoning, “extreme” illogicality or rationality must be shown, “measured against the standard that it is not enough for the question of fact to be one on which reasonable minds may come to different conclusions”. And as McKerracher J (with whom Reeves J agreed) emphasised in SZOOR v Minister for Immigration and Citizenship (2012) 202 FCR 1 (at [84]), a decision cannot be said by a reviewing court to be illogical, irrational or unreasonable simply because one conclusion has been preferred to another possible conclusion.

    [55] Nevertheless, allegations of illogical or irrational reasoning or findings of fact must be considered against the framework of the inquiry being whether or not there has been jurisdictional error on the part of the Tribunal: SZRKT at 137 [148]. The overarching question is whether the Tribunal’s decision was affected by jurisdictional error: SZRKT at 137-138 [151]. Even if an aspect of reasoning, or a particular factual finding, is shown to be irrational or illogical, jurisdictional error will generally not be established if that reasoning or finding of fact was immaterial, or not critical to, the ultimate conclusion or end result: Minister for Immigration and Citizenship v SZOCT (2010) 189 FCR 577 at 598-599 [83]-[84] (Nicholas J); SZNKO v Minister for Immigration and Citizenship [2013] FCA 123 at [113]. Where the impugned finding is but one of a number of findings that independently may have led to the Tribunal’s ultimate conclusion, jurisdictional error will generally not be made out: SZRLQ v Minister for Immigration and Citizenship (2013) 135 ALD 276 at 291 [66]; SZWCO at [64]-[67].”

  2. As to the applicants’ second claim, the Court accepts the submissions made on behalf of the first respondent that the mission/vision statement of the Foundation was not such as to constitute a call to overthrow the Vietnamese government. There was a distinction between what the first applicant might have been represented as having said as recorded in a video and what was recorded by the Authority as evidencing the actual ideals of the Foundation as set out in its mission/vision statement. The Authority said as much at [43] of its reasons as follows:

    “[43] I accept the first applicant's involvement with IYMFHR has included participation in conferences or meetings, and attendance at various peaceful demonstrations. I am also prepared to accept he is a member and holds a position on a committee within the organisation, that he has been involved with the organisation of some of the events he has attended, and that he has spoken at events. The delegate referred to the official website for IYMFHR, which states their mission and vision to engage, inspire and mobilise the youth communities in Vietnam and abroad to transform human rights conditions in Vietnam, and to connect young people around the world to create effective, real change for the advancement of freedom and democracy in Vietnam through human rights foundation. I do not consider the mission and vision of the IYMFHR indicative of an organisation attempting to overthrow the Vietnamese government, or being against the state, such that the applicant would be imputed with a political profile as a result of his participation in the organisation, even accepting his role as an organiser and committee member. No evidence has been provided to indicate that Vietnamese authorities view IYMFHR as a threat. I accept there is a possibility Vietnamese authorities might become aware of the first applicant's activities in Australia through viewing the video compilation, or by viewing his photograph associated with an online media article, but I consider this a remote one. Of note, the online photographs do not mention the first applicant by name, and reveal nothing more than his attendance at the event at which they were taken. Taking into account the nature of the video compilation, which it is very apparent on its face was produced to draw attention to the first applicant's involvement in activities in Australia and bolster his Visa application, and does not genuinely reflect any strong anti-Vietnamese government opinions he holds, I consider if Vietnamese authorities were to view the video it is extremely unlikely they would seriously consider the first applicant as a high profile political activist or dissident, or regard this material as the type to be censored or blocked. I am satisfied Vietnamese authorities would assess the first applicant as being a low-level participant in political activities and protests in Australia, albeit critical of the government, which country information indicates would not lead to him having an adverse profile on return. There is nothing in the evidence before me to indicate the first applicant was engaged in any political activities or organisations previously in Vietnam, or that he intends to participate on return. I am not convinced the first applicant has any genuine interest in political activism, or any intention or interest in participating in such activities upon return, and I am not satisfied any non-participation would be because of any fear of persecution.”

  3. The Authority did not consider that the first applicant had any adverse profile within the Vietnamese government in the sense that he might be considered an anti-government dissident, blogger, political or human rights activist, or that he would be perceived as such in the reasonably foreseeable future. To the extent that the applicants cavil with the decision of the Authority in that regard, they ask that this Court undertake an impermissible merits review.

  4. As to the third of the applicants’ claims, the Authority was entitled to find that the first applicant had associated himself with the Foundation for the purpose of strengthening his refugee claim contrary to the provisions of s. 5J(6) of the Act. At [18] – [23] inclusive of its reasons, the Authority found that the first applicant had caused such video compilation to be prepared for the purpose of advancing his migration application contrary to the provisions of s. 5J(6) of the Act. Section 5J(6) relevantly provided as follows:

    5J Meaning of well-founded fear of persecution

    (1)       …

    (2)       …

    (6) In determining whether the person has a well‑founded fear of persecution for one or more of the reasons mentioned in paragraph (1)(a), any conduct engaged in by the person in Australia is to be disregarded unless the person satisfies the Minister that the person engaged in the conduct otherwise than for the purpose of strengthening the person’s claim to be a refugee.”

  5. Such finding was made even though the Authority had accepted that the first applicant had been involved with the Foundation in 2017 and 2018, and that he was vice-president of a committee of such foundation.

  6. At [22] of its reasons, the Authority carefully analysed the timeframe within which various of the first applicant’s activities occurred, finding that certain activities could not be characterised as being merely coincidental. It was entitled to arrive at such conclusion. It did so having appropriately weighed up all of the evidence before it.

  7. Neither could the decision of the Authority be considered as legally unreasonable, or one lacking an evident and intelligible justification, as such respective concepts were considered by Hayne, Kiefel and Bell JJ in Minister for Immigration and Citizenship v Li (2013) 249 CLR 332 at [66] and [76] where it was said:

    “[66] This approach does not deny that there is an area within which a decision-maker has a genuinely free discretion. That area resides within the bounds of legal reasonableness. The courts are conscious of not exceeding their supervisory role by undertaking a review of the merits of an exercise of discretionary power. Properly applied, a standard of legal reasonableness does not involve substituting a court's view as to how a discretion should be exercised for that of a decision-maker. Accepting that the standard of reasonableness is not applied in this way does not, however, explain how it is to be applied and how it is to be tested.

    [76] As to the inferences that may be drawn by an appellate court, it was said in House v The King that an appellate court may infer that in some way there has been a failure properly to exercise the discretion "if upon the facts [the result] is unreasonable or plainly unjust". The same reasoning might apply to the review of the exercise of a statutory discretion, where unreasonableness is an inference drawn from the facts and from the matters falling for consideration in the exercise of the statutory power. Even where some reasons have been provided, as is the case here, it may nevertheless not be possible for a court to comprehend how the decision was arrived at. Unreasonableness is a conclusion which may be applied to a decision which lacks an evident and intelligible justification.”

  8. The first applicant’s claim for protection and complementary protection were dealt with in a considered and careful way by the Authority. The Authority found that the first applicant did not fall under either ss. 36(2)(a) or 36(2)(aa) of the Act. It did not err in doing so.

  9. The success of the claims of the second, third and fourth applicants was dependent upon the success of the first applicant’s claims.

  10. The applicants have failed to establish jurisdictional error on the part of the Authority.

  11. The Originating Application for Review is without merit and is dismissed.

  12. The Court will hear the parties as to costs.

I certify that the preceding twenty-seven (27) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Egan.

Associate:

Dated:       31 March 2021

SCHEDULE OF PARTIES

ADG 114 of 2019

Applicants

Fourth Applicant:

BIW19

Areas of Law

  • Administrative Law

  • Immigration

  • Statutory Interpretation

Legal Concepts

  • Judicial Review

  • Natural Justice

  • Procedural Fairness

  • Statutory Construction

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