Chen (Migration)

Chen (Migration) [2017] AATA 2551 (25 August 2017)
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DECISION RECORD

DIVISION:Migration & Refugee Division
APPLICANTS:  Mr Dezhen Chen
Ms Yuerong Zhang
Mr Jilong Chen
CASE NUMBER:  1706986
DIBP REFERENCE(S):  BCC2017/340725
MEMBER:Katie Malyon
DATE:25 August 2017
PLACE OF DECISION:  Sydney
DECISION:The Tribunal affirms the decision to cancel the first named applicant’s Subclass 457 (Temporary Work (Skilled)) visa.
The Tribunal has no jurisdiction with respect to the second and third named applicants.

Statement made on 25 August 2017 at 11:13 am

CATCHWORDS
Migration – Cancellation – Temporary Business Entry (Class UC) visa – Subclass 457 (Temporary Work (Skilled)) – Sponsoring business ceased trading – Business no longer lawfully operating – Ceased work over 90 days – Visa expiry date has passed – No evidence the applicant remained employed – No evidence of a new sponsoring employer
LEGISLATION
Migration Act 1958, ss 116, 140, 348, 359, 360, 363
Migration Regulations 1994, Schedule 2 cl 457.223, 2.72
CASES
Drake v MIEA (No 2) (1979) 2 ALD 634;
Jasbeer Singh v MIEA (Federal Court of Australia, 1994)
McDonald v D-G of Social Security (1984) 1 FCR 354
Mian v MILGEA (1992) 28 ALD 165
MIEA v Wu Shan Liang (1996) 185 CLR 259
Nagalingam v MILGEA & Anor (1992) 38 FCR 191
Qiao v MIAC (2008) FMCA 380
Rani & Ors v MIMA (1997) 80 FCR 379 at 385, 393, 400
Swan Television & Radio Broadcasters Ltd v ABT (1985) 8 FCR 291
Tien & Ors v MIMA (1998) 89 FCR 80
Zhao v Minister for Immigration and Multicultural Affairs (2000) FCA 1235
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 on 30 March 2017 to cancel the Subclass 457 Temporary Business Entry (Class UC) visas of the applicants under s.116 of the Migration Act 1958 (the Act).
The delegate cancelled the visa under s.116(1)(aa) of the Act on the basis that the decision to grant a Subclass 457 visa to the primary applicant, Mr Dezhen Chen, was based – wholly or partly – on a particular fact or circumstance that was no longer the case or that no longer exists. As indicated in the delegate’s decision, a copy of which was provided to the Tribunal, this was because:
·the standard business sponsor which nominated Mr Chen in the most recently approved nomination, Liz-Con Concrete Constructions Pty Ltd (the Company), had its nomination for the position of Bricklayer in respect of Mr Chen approved on 22 March 2016;
·Mr Chen’s Subclass 457 visa was approved on 22 March 2016;
·on 12 January 2017, the Department received written notice from Jones Partners, Chartered Accountants specialising in Insolvency and Business Recovery (Jones Partners) that it had been appointed Liquidator of the Company on 22 February 2016 pursuant to an Order of the Supreme Court of New South Wales. The written notice confirmed that the Company ceased trading prior to appointment of Jones Partners as Liquidator and, accordingly, the Company had ceased trading on or before 22 February 2016; and,
·as the Company had ceased trading at the time the nomination was approved, it could not be considered to be an approved business sponsor for the purposes of r.2.72 of the Migration Regulations 1994 (the Regulations). One of the requirements for being an approved business sponsor is that the business must be lawfully operating. Because the Company was not lawfully operating, the nomination was not made by an approved business sponsor and, as a result, the circumstances that enabled Mr Chen to meet criteria for grant of the visa did not exist at the time of the decision to grant his Subclass 457 visa.
For the purposes of the Tribunal’s jurisdiction under s.348 of the Act, the only decision that is before the Tribunal is the decision with respect to Mr Chen, the first named applicant. The visa of the second named applicant, Mr Chen’s wife Ms Yuerong Zhang, and the third named applicant, his son Jilong Chen, were automatically cancelled as a consequence of cancellation of Mr Chen’s Subclass 457 visa, not by a decision but by force of the operation of s.140(1) of the Act which made the cancellation of the Subclass 457 visas of both Ms Zhang and Mr Chen’s son’s Subclass 457 visas self-executing on the cancellation of Mr Chen’s visa: see Rani & Ors v MIMA (1997) 80 FCR 379 at 385, 393, 400; Tien & Ors v MIMA (1998) 89 FCR 80 at 96. As no decision was involved in their visa cancellation under s.140(1) of the Act, the Tribunal has no jurisdiction with respect to Ms Zhang and Mr Chen’s son, Jilong Chen.
The issue in the present case is whether the ground for cancellation of Mr Chen’s Subclass 457 visa is made out, and if so, whether his visa should be cancelled.
It is well established that civil law concepts such as onus and standard of proof are generally inappropriate in the administrative law context.[1] However where, as in cancellation cases, the existence of facts grounds the exercise of a statutory power, the onus of establishing the facts is on the Minister (or on review, the Tribunal).[2] Although the visa holder must be invited to show that the ground does not exist, or if it does, to show cause why the discretion should not be exercised, this does not place an onus on the visa holder to establish at that point that the visa should not be cancelled.[3] As French, Hill and Carr JJ said in Zhao v Minister for Immigration and Multicultural Affairs [2000] FCA 1235 at [25]:
“The decision-maker, acting under s 116, must be satisfied of one or other of the matters set out in that section before the visa can be cancelled. That state of satisfaction is a real state of satisfaction which must be reached on a consideration of the available material. A visa cannot be cancelled simply because the visa holder has failed to show cause why it should not.”
[1] MIEA v Wu Shan Liang (1996) 185 CLR 259 at 282-3; Nagalingam v MILGEA & Anor (1992) 38 FCR 191 at 200; McDonald v D-G of Social Security (1984) 1 FCR 354 at 357; Swan Television & Radio Broadcasters Ltd v ABT (1985) 8 FCR 291 at 297.
[2] Mian v MILGEA (1992) 28 ALD 165 at 169; Jasbeer Singh v MIEA (unreported, Federal Court of Australia, Sackville J, 6 December 1994) at [14].
[3] See Zhao v MIMA [2000] FCA 1235, French, Hill & Carr JJ, 1 September 2000.
Following an examination of the publicly available information on the website of the Australian Securities and Investment Commission (ASIC), the Tribunal has independently confirmed that the Company was the subject of a Liquidation Order issued by the Supreme Court of New South Wales on 22 February 2016.
On 31 July 2017, the Tribunal wrote to Mr Chen pursuant to s.359A and s.359(2) of the Act at the email address provided in his review application. It invited him to comment on or respond to information which the Tribunal considers would, subject to his comments or response, be the reason or part of the reason for affirming the delegate’s decision as well as provide information. The letter states as follows:
“I am writing in relation to the application for review made by you in respect of a decision to cancel a Subclass 457 visa.
Invitation to comment on or respond to information
In conducting this review, the Tribunal is required by the Migration Act to 1958 (the Act) to invite you to comment on or respond to certain information which the Tribunal considers would, subject to your comments or response, be the reason, or a part of the reason, for affirming the decision under review.
Please note, however, that the Tribunal has not made up its mind about the information.
The particulars of the information are:
1.The decision to grant you a Subclass 457 visa was based, wholly or partly, on the existence of a particular fact or circumstance, and that fact or circumstance did not exist – s.116(1)(aa) of the Act
·     You were granted a Subclass 457 visa on 22 March 2016.
·     The nomination application lodged by your sponsor Lis-Con Concrete Constructions Pty Ltd (the Company) was approved on 22 March 2016.
·     On 22 February 2016 (that is, 1 month before approval of the nomination) the Supreme Court of New South Wales appointed a Liquidator to the Company.
·     The Department’s file confirms advice from the Liquidator that the Company ceased trading prior to appointment of the Liquidator.
This information is relevant because the Tribunal may find as the Company had ceased trading at the time the nomination was approved it could not be considered an approved sponsor. The Tribunal may find that grounds exist for cancelling your visa under s.116(1)(aa) of the Act.
2.Breach of condition – s.116(1)(b) of the Act
·     You were granted a Subclass 457 visa on 22 March 2016 on the basis of sponsorship by the Company.
·     As the Company was a standard business sponsor your Subclass 457 visa was granted under cl.457.223(3) of Schedule 2 of the Migration Regulations 1994 (the Regulations) and, accordingly, visa condition 8107(3) is applicable to your Subclass 457 visa.
·     Condition 8107(3) requires you to work only in the occupation listed in the most recently approved nomination in relation to you, and only in the business of your sponsor, or an associated entity. In addition, if the visa was granted when you were outside Australia then you must commence work (with your sponsor) within 90 days of your arrival and, if you cease employment, the period during which you cease employment must not exceed 60 consecutive days.
This information is relevant because the Tribunal may find that you have not complied with condition 8107 and that there are grounds for cancelling your Subclass 457 visa under s.116(1)(b) of the Act which, relevantly, permits a Subclass 457 visa to be cancelled for breach of a visa condition.
3.Exercise of discretion
·          Your Subclass 457 visa was granted on 22 March 2016 and was due to expire on 30 March 2017.
This information is relevant because, if the Tribunal finds that grounds for cancelling your Subclass 457 visa exist, the Tribunal will then consider whether or not your visa should be cancelled. The fact that your Subclass 457 visa has now expired, had it not been cancelled by the Department, would be relevant to the Tribunal’s exercise of its discretion.
You are invited to provide comments on or respond to the above information in writing.
Invitation to provide information
If the Tribunal determines that there are grounds for cancelling your Subclass 457 visa, the Tribunal will then consider whether or not your visa should be cancelled. The Tribunal may have regard to the following matters:
·     the purpose of your travel to and stay in Australia;
·     the extent of your non-compliance with any conditions subject to which your visa was granted;
·     the circumstances in which the ground for cancellation arose;
·     your behaviour in relation to the Department, now and on previous occasions;
·     the degree of hardship which may be caused to you and any family members including children. If there are children in Australia whose interests could be affected by cancellation of the visa, or who themselves would be affected by consequential cancellation, then decision-makers such as the Tribunal have an obligation to treat as a primary consideration the effect of cancellation on any such children;
·     whether cancellation would lead to removal in breach of Australia’s non-refoulement obligations;
·     other matters you wish to raise.
The Tribunal invites you to provide information you wish to have the Tribunal consider in relation to these matters.
Timeframe to give comments or response and provide information
Your comments or response and the information should be received by 14 August 2017. If the comments or response or information are not in a language other than English, they must be accompanied by an English translation from an accredited translator.
If you cannot provide either the written comments or response or the information or
both by 14 August 2017, you may ask us for an extension of time. If you make such
a request, it must be received by us before 14 August 2017 and you must state the
reason why the extension of time is required.
We will carefully consider any request for an extension of time and will advise whether
or not the extension has been granted.
Consequences of not responding to either invitation
If we do not receive either your comments or response or the information within the
period allowed or as extended, we may make a decision on the review without taking
any further action to obtain your views on the information or to obtain the information.
You will also lose any entitlement you might otherwise have had under the
Migration Act to appear before us to give evidence and present arguments.
If you have any questions, please email [email protected], or contact me on the
number listed below, or telephone our national enquiry line on 1800 228 333.”
Mr Chen did not respond to the Tribunal’s letter. As Mr Chen did not provide the information within the prescribed period and no extension was requested, s.359C of the Act applies and, pursuant to s.360(3) of the Act, the review applicant is not entitled to appear before the Tribunal. The effect of s.363A of the Act is that, if a review 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 has decided to proceed to a decision without taking further steps to obtain comments or a response from Mr Chen or obtain the information from him.
For the following reasons, the Tribunal has concluded that the decision to cancel Mr Chen’s Subclass 457 visa should be affirmed.
CONSIDERATION OF EVIDENCE
Under s.116 of the Act, the Minister may cancel a visa if he or she is satisfied that certain grounds specified in that provision are made out. Relevant to this case, these include the ground set out in s.116(1)(aa) of the Act. If satisfied that the ground for cancellation is made out, the decision maker must proceed to consider whether the visa should be cancelled having regard to all the relevant circumstances, which may include matters of government policy.
Background
Mr Chen is a 43 year old national of China. He was granted a Subclass 457 visa on 22 March 2016 on the basis of an approved nomination in the occupation of Bricklayer lodged by his sponsor, the Company. His wife and son were also granted Subclass 457 visas on 22 March 2016 on the basis of being members of Mr Chen’s family unit.
As indicated in the delegate’s decision, a copy of which was provided to the Tribunal, a Liquidator was appointed to the Company on 22 February 2016. On 8 March 2017 - that is, more than 12 months after the appointment of Liquidator - the Department issued Mr Chen a Notice of Intention to Consider Cancellation (NOICC) of his Subclass 457 visa under s.116 of the Act. It did so on the basis that it had received written notice from Jones Partners that it was appointed Liquidator of the Company on 22 February 2016 pursuant to an Order of the Supreme Court of New South Wales and that the Company had ceased trading prior to its appointment as Liquidator. The delegate stated in the NOICC that, in the circumstances, the Company appears to have ceased trading on or before 22 February 2016. However, a month later on 22 March 2016, the Company’s nomination was approved in respect of Mr Chen and he was granted a Subclass 457 visa. One of the requirements of being an approved sponsor is that the sponsor’s business must be lawfully operating and, given the sponsor had ceased trading at the time the nomination was approved, the Company could not be considered to be an approved sponsor. Consequently, the nomination was not made by an approved business sponsor and, as a result, the circumstances which enabled Mr Chen to meet criteria for grant of his visa did not exist at the time of the decision to grant his Subclass 457 visa.
Mr Chen responded to the NOICC on 24 March 2017 stating that he did:
“not know my company has been closed down. The news came suddenly. And our family came to Australia about a year, and I worked diligently at work, my wife is here. My son isi n high school. I looked at my son happy day by day, day by day cheerful, my heart sincerely feel happy. However, I do not think this news should tell my son, make him sad, so I asked (sic) the government can give me an extra 2 months time pleases (sic), let me use my work skills to find a new employer, but also for my son.”
ASIC’s website states that liquidation is the orderly winding up of a company’s affairs.[4] A court liquidation starts as a result of a Court Order, made after an application to the court, typically by a creditor of the company. The purpose of liquidation of an insolvent company is to have an independent and suitably qualified person, the liquidator – in this case, Jones Partners - take control of the company so that its affairs can be wound up in an orderly and fair way for the benefit of creditors. In most cases, the liquidation of a company terminates the employment of all employees. However, a liquidator may continue to trade the business for a short period to assist in the winding up.
[4] the ground for cancellation exist?
The Tribunal has independently established from the ASIC’s website that the Company was the subject of a Liquidation Order issued by the Supreme Court of New South Wales on 22 February 2016. As noted in the delegate’s decision and referred to in the Tribunal’s letter sent to Mr Chen on 31 July 2017, Jones Partners had informed the Department on 12 January 2017 that the Company ceased trading prior to its appointment as Liquidator. Based on this evidence, the Tribunal finds that the Company had ceased trading at the time the Company’s nomination was approved on 22 March 2016.
One of the requirements for being an approved sponsor is that the business must be lawfully operating. Given the Company had ceased trading at the time its nomination was approved, the Company could no longer be considered to be an approved sponsor. The Tribunal finds that the nomination made by the Company in respect of Mr Chen was not made by an approved sponsor and, accordingly, the circumstances that enabled Mr Chen to meet criteria for grant of a Subclass 457 visa did not exist at the time of the Department’s decision to grant him the visa on 22 March 2016.
Although in his response to the NOICC Mr Chen states that he did not know the Company had been ‘closed down’ and, further, that since arriving in Australia he has ‘worked diligently’ at his work, no evidence was provided to the Department in support of these claims. Furthermore, despite the delegate’s decision referring to the absence of evidence of Mr Chen’s claims in this regard, he did not provide any evidence to support his claims when lodging his application for review with the Tribunal. Moreover, Mr Chen did not respond to the Tribunal’s letter (extracted above) issued pursuant to s.359A and s.359(2) of the Act on 31 July 2017.
Having regard to evidence before the Tribunal and the findings referred to above, the Tribunal is satisfied that a fact or circumstance leading to grant of Mr Chen’s Subclass 457 visa on 22 March 2016 no longer existed: his sponsor had gone into liquidation on 22 February 2016 and was no longer actively operating. Accordingly, the Tribunal is satisfied that the ground of cancellation of Mr Chen’s visa under s.116(1)(aa) of the Act is made out. As that ground does not require mandatory cancellation under s.116(3) of the Act, the Tribunal must proceed to consider whether the power to cancel the visa should be exercised.
Consideration of discretion
There are no matters specified in the Act or Regulations that are required to be considered in relation to the exercise of the discretion to cancel the visa. However, in considering whether to exercise its discretion to cancel the applicant’s visa, the Tribunal has had regard to the relevant circumstances including, but not limited to, matters identified in the Department’s Procedures Advice Manual PAM3 ‘General visa cancellation powers’.

In exercising its power to cancel a visa, the Tribunal should have regard to policy as a relevant consideration. However, policy is not binding on the Tribunal.[5] The overarching principle is that the Tribunal must make an independent assessment of the material before it with a view to reaching the correct or (in the case of the exercise of a discretionary power, as in this matter) the preferable decision.[6]
The purpose of the visa holder’s travel to and stay in Australia
[5] Re Drake v MIEA (No 2) (1979) 2 ALD 634; Qiao v MIAC [2008] FMCA 380
[6] See Hneidi v MIAC [2010] FCAFC 20 (Spender, Emmett and Jaocobson JJ) at [34]
Mr Chen was granted his Subclass 457 visa for the purpose of being able to fill a skills shortage in the occupation of Bricklayer and work in Australia for an approved sponsor. When the Department received written notice from Jones Partners that it had been appointed Liquidator of the Company on 22 February 2016 pursuant to an Order of the Supreme Court of New South Wales and, further, that the Company had ceased trading before that date, it is clear that the purpose for grant of Mr Chen’s Subclass 457 visa no longer existed from at least 22 February 2016.
Since Mr Chen’s Subclass 457 visa was granted under cl.457.223(4) of Schedule 2 of the Regulations, visa condition 8107(3) is applicable to his visa. This requires Mr Chen to work only in the occupation listed in the most recently approved nomination in relation to him, and only in the business of his sponsor, or an associated entity. In addition, if he ceases employment, the period during which he ceases employment must not exceed 90 consecutive days. There is an exception which includes certain specified occupations not applicable in this case.
In response to the Department’s NOICC, Mr Chen indicated that he had ‘worked diligently’ since arriving in Australia. However, as noted in the delegate’s decision, no evidence was provided to the Department about who is his employer or the nature or location of his work. Furthermore, although visa condition 8107(3) allows 90 days for a Subclass 457 visa holder to find an alternate employer to sponsor them if they cease to work with their sponsor, Mr Chen has not provided any evidence of a new nomination being lodged by a proposed sponsor/employer. In addition, he did not respond to the Tribunal’s letter issued pursuant to s.359A and s.359(2) of the Act. In this regard, not only did the Tribunal’s letter raise the issue of whether he had breached condition 8107(3) attached to his Subclass 457 visa but it also noted that his visa was due to expire on 30 March 2017, that is, nearly 5 months ago.
Having regard to the fact that the Company was placed in liquidation prior to Mr Chen’s arrival in Australia, the Tribunal is satisfied that he has never worked with the Company. Accordingly, the purpose of Mr Chen’s travel to and stay in Australia came to an end 90 days after his arrival in Australia. His Subclass 457 visa expired on 22 March 2017. The Tribunal’s review of Departmental records confirms that no new nomination has been lodged in relation to Mr Chen.
The Tribunal gives weight to these considerations in favour of cancelling the visa.
Extent of compliance with visa conditions, now and on previous occasions
As noted above, in response to the NOICC issued by the Department, Mr Chen stated that he has been working diligently after arriving in Australia on 1 April 2016. Since his sponsor ceased trading on before 22 February 2016 it appears Mr Chen has not been employed by the Company. No evidence has been provided to contradict this. In the circumstances, the Tribunal finds that Mr Chen has not complied with condition 8107 attached to his Subclass 457 visa.
The Tribunal gives weight to this consideration in favour of cancelling the visa.
The circumstances in which the ground for cancellation arose
The circumstances giving rise to the Department’s cancellation of Mr Chen’s Subclass 457 visa on 30 March 2017 arose from the Department becoming aware that a Liquidator had been appointed to the Company on 22 February 2016 and that it had ceased to operate before then.
The Tribunal accepts that the circumstances in which the ground to cancellation arose were, essentially, beyond Mr Chen’s control. A Subclass 457 visa is a temporary visa allowing skilled foreign nationals to fill vacancies to work in Australia consistent with conditions attached to their visa: it is a temporary visa for a specific purpose which, in Mr Chen’s case, has ceased. In the opinion of the Tribunal, it is incumbent upon all visa holders to be familiar with the conditions attached to their visa and their work rights in Australia. Accordingly, it would have been open for Mr Chen, upon his arrival in Australia, to seek a new employer to take over sponsorship of his Subclass 457 visa.
The Tribunal gives weight to these considerations in favour of cancelling the visa.
Visa holder’s past and present behaviour towards Department (and the Tribunal)
As noted in the delegate’s decision, Mr Chen responded on 24 March 2017 to the NOICC issued by the Department on 8 March 2017. However, he provided no evidence of the entity he claims to have been working with: nor did he provide details of the nature of the role that he has been undertaking. Further, Mr Chen did not respond to the Tribunal’s letter issued pursuant to s.359A and s.359(2) of the Act.
The Tribunal gives weight to these considerations in favour of cancelling the visa.
Degree of hardship
The Tribunal has also considered the hardship that may be caused if Mr Chen’s Subclass 457 visa is cancelled. In his response to the NOICC, Mr Chen notes that his son Jilong Chen is attending high school. He describes his son as ‘happy day by day, day by day cheerful’ and, as a result, Mr Chen is also ‘sincerely happy’.
While the Tribunal accepts that leaving Australia would involve some adjustment for Mr Chen and his family it is nonetheless of the view that any difficulties would not be significant.
The Tribunal gives little weight to these considerations in favour of not cancelling the visa.
Whether there would be consequential cancellations under s.140 of the Act
Cancellation of Mr Chen’s Subclass 457 visa has also lead to cancellation of the visas of his wife and 17 years old son. Apart from Mr Chen’s observations in his response to the NOICC referred to above regarding his son’s attendance at high school as well as his son’s disposition no other evidence was provided to the Department - or the Tribunal - regarding the impact of cancellation of his family’s Subclass 457 visas. In this regard, the Tribunal notes no evidence was provided of the name of the school his son is attending, his progress at school nor his son’s involvement in sport or other extra-curricular activities. Mr Chen made no comments about his wife, apart from noting that she is in Australia with him.
The Tribunal gives little weight to consideration of Mr Chen’s family’s consequential visa cancellation under s.140 of the Act in not cancelling Mr Chen’s visa.
Whether there are mandatory legal consequences to a cancellation decision
The Tribunal finds that affirming the cancellation of Mr Chen’s Subclass 457 visa would result in him being unlawful if he does not leave Australia in the permitted time and he and his family may thereby be subject to being detained at a Detention Centre. The Tribunal gives little weight to this consideration in not cancelling the visa.
Mr Chen currently holds a Bridging E visa with no work rights. He applied for his Bridging E visa 7 weeks after cancellation of his Subclass 457 visa. Accordingly, if he wishes to apply for another Subclass 457 visa from overseas, he will be subject to a risk factor under Public Interest Criteria 4014.
The Tribunal gives no weight to this consideration in not cancelling the visa.
Whether obligations under international agreements would be breached
There is nothing to suggest that any international obligations would be breached as a result of cancellation of Mr Chen’s Subclass 457 visa. He made no submissions in this regard.
The Tribunal gives no weight to this consideration in not cancelling the visa.
Conclusion
Having considered all of the circumstances in this case and the evidence before it, the Tribunal is satisfied that the evidence in favour of cancelling Mr Chen’s Subclass 457 visa strongly outweighs that in favour of not cancelling his visa. For the reasons outlined above, the Tribunal has formed the view that this is not an appropriate case to exercise its discretion and set aside cancellation of Mr Chen’s Subclass 457 visa.
Considering the circumstances as a whole, the Tribunal concludes that the visa should be cancelled.
DECISION
The Tribunal affirms the decision to cancel the first named applicant’s Subclass 457 (Temporary Work (Skilled)) visa.
The Tribunal has no jurisdiction with respect to the second and third named applicants.
Katie Malyon

Member

[2017] AATA 2551

25 August 2017

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Statutory Construction

Jurisdiction

Remedies