CHO18 v Minister for Immigration and Multicultural Affairs
[2025] FedCFamC2G 17
•14 January 2025
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 2)
CHO18 v Minister for Immigration and Multicultural Affairs [2025] FedCFamC2G 17
File number(s): SYG 1269 of 2018 Judgment of: JUDGE LAING Date of judgment: 14 January 2025 Catchwords: MIGRATION – application for judicial review of a decision by the Immigration Assessment Authority (“IAA”) – whether the IAA misapplied s 473DD of the Migration Act 1958 (Cth) – application dismissed Legislation: Immigrants and Emigrants Act 1949
Migration Act 1958 (Cth) ss 5J & 473DD
Cases cited: AAQ18 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 759
AUS17 v Minister for Immigration and Border Protection [2020] HCA 37; (2020) 269 CLR 494
BVZ16 v Minister for Immigration and Border Protection [2017] FCA 958; (2017) 254 FCR 221
DZU17 v Minister for Immigration and Border Protection [2019] FCCA 491
Minister for Immigration and Citizenship v SZMDS [2010] HCA 16; (2010) 240 CLR 611
Division: General Number of paragraphs: 34 Date of hearing: 5 November 2024 Place: Sydney Counsel for the Applicant: Mr G Foster Solicitor for the Applicant: Sentil Solicitor Counsel for the First Respondent: Mr T Reilly Solicitor for the First Respondent: HWL Ebsworth Lawyers Second Respondent: Submitting appearance, save as to costs ORDERS
SYG 1269 of 2018 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)
BETWEEN: CHO18
Applicant
AND: MINISTER FOR IMMIGRATION AND MULTICULTURAL AFFAIRS
First Respondent
IMMIGRATION ASSESSMENT AUTHORITY
Second Respondent
ORDER MADE BY:
JUDGE LAING
DATE OF ORDER:
14 JANUARY 2025
THE COURT ORDERS THAT:
1.The application be dismissed.
Note: The form of the order is subject to the entry in the Court’s records.
Note: The Court may vary or set aside a judgment or order to remedy minor typographical or grammatical errors (r 17.05(2)(g) Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 17.05 Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth).
REASONS FOR JUDGMENT
JUDGE LAING:
The applicant seeks judicial review of a decision of the Immigration Assessment Authority (IAA) (as it was). The IAA affirmed a decision of a delegate (Delegate) of the first respondent (Minister) refusing to grant the applicant a Safe Haven Enterprise (Class XE) (Subclass 790) visa (protection visa).
BACKGROUND
The applicant is a Sri Lankan national who applied for the protection visa that is the subject of these proceedings on 21 July 2016.
On 19 July 2017, the Delegate refused the application. The matter was then referred to the IAA for review.
On 17 April 2018, the IAA affirmed the Delegate’s decision.
THE IAA’S DECISION
The IAA observed that new information had been provided by the applicant on 16 August 2017. The IAA was not satisfied that the requirements of s 473DD of the Migration Act 1958 (Cth) (Act) were met in relation to the new information (at [4]-[8]). The IAA’s reasoning in this regard will be the subject of further consideration below.
The IAA accepted that:
(a)the applicant was a Tamil of the Hindu faith from the area of Sri Lanka claimed (at [10]);
(b)the applicant’s father supported the Liberation Tigers of Tamil Eelam (LTTE) cause, that he supported the organisation with the gift of a bullock cart, a motor bike and food and that the family home and farm were located in the area claimed (at [11]);
(c)the applicant may have attended an LTTE Heroes Day event as part of his school activities (at [12]);
(d)the Sea Tigers established a small, temporary base on his father’s land in 2006 (at [13]);
(e)the applicant visited the base two or three times per week, helped the cadres with the cleaning and greasing of their weapons and kept his visits to the camp secret from his parents for a period of time (at [14]);
(f)the applicant may have stood sentry with an LTTE cadre at the base on one occasion (at [15]);
(g)the applicant’s mother was able to prevent his recruitment in 2006 by arguing that the family had provided considerable support to the LTTE at that point (at [16]);
(h)the family was required to leave their home in 2006 when the Sri Lankan Army (SLA) began attacking the base (at [17]);
(i)the family and the family farm may have been the subject of Criminal Investigation Division (CID) enquiries after the end of the war (at [22]);
(j)the CID may have visited the family in 2009 and questioned the applicant and his father about possible LTTE weapons buried on the property (at [23]);
(k)the CID made the applicant and his father dig in and around the farm house in search of buried weapons. However, the IAA considered that the fact that the CID did not take his father into detention or physically mistreat the family indicated that the applicant and his father were not of serious concern to the CID at the time (at [23]);
(l)the applicant may have subsequently been stopped by the same CID officers asking about weapons (at [25]);
(m)the applicant’s education may have been disrupted both during and after the conflict (at [28]); and
(n)the applicant attended an LTTE Heroes Day event in Australia in 2015 (at [32]).
The Tribunal did not accept that:
(a)the applicant and his family were permitted by the SLA to return to their farm while the conflict was still underway (at [20]);
(b)the CID knew the applicant had been inside the base from information received from ex-LTTE cadres or local villagers (at [21]);
(c)between 2009 and 2013, the CID officers continually visited the farm two or three times per month, or that in 2013, the CID officers interrogated and threatened the applicant more intensively than before about the weapons (at [26]-[27]);
(d)the applicant left school for a period because of CID interest in the family, or because it was dangerous for him to travel (at [28]);
(e)had the applicant remained in Sri Lanka, he would have been arrested (at [30]);
(f)the CID visited the applicant’s home in 2014 and told his parents that they knew he had departed Sri Lanka and that if he returned, he would be arrested (at [31]); or
(g)photos of the applicant at the 2015 event were posted to social media, or that he was filmed (at [32]).
While the IAA accepted that the CID had searched and investigated the applicant’s family regarding a suspected weapons cache, it found that they were never arrested, detained, or taken into custody for questioning. The IAA did not accept that the applicant was a person of any interest to the Sri Lankan authorities at the time he departed Sri Lanka (at [35]).
The IAA did not accept that the applicant’s activities, including attending a Heroes Day event in Sri Lanka and in Australia, would be perceived by the Sri Lankan government as causes for concern, in circumstances where the applicant had never been an activist or involved in separatist activities (at [36]).
Having regard to country information and the applicant’s profile, the IAA was not satisfied that the applicant would face a real chance of harm on return to Sri Lanka because of his identity as a Tamil male from the area claimed, because of his and his father’s connections to the LTTE, or because of his attendance at Heroes Day events (at [39]).
The IAA accepted that there was a possibility that the applicant’s family farm contained uncleared munitions, however, the IAA considered the risk from this to be remote. The IAA was not satisfied that the applicant would face a real chance of harm on account of unexploded ordinance or uncleared landmines on the family farm. The IAA was also not satisfied that any harm, were it to occur, would be for one or more of the reasons specified in s 5J(1) of the Act (at [40]).
The IAA accepted that the applicant may be questioned and charged under the Immigrants and Emigrants Act 1949 on account of his illegal departure from Sri Lanka. The IAA accepted that the applicant may be detained for a limited period in unpleasant conditions and incur a fine. The IAA did not consider that such penalties or processes would be discriminatory. The IAA did not accept that they would amount to serious harm or persecution, nor did the IAA accept that the results would meet the definition of significant harm. The IAA was therefore not satisfied that the applicant faced a real chance of persecution or significant harm on account of his illegal departure (at [41]-[49] and [54]).
Having regard to the above, the IAA concluded that the applicant was unable to meet the criteria for a protection visa and affirmed the Delegate’s decision (at [50]-[55]).
PROCEEDINGS BEFORE THIS COURT
The applicant commenced the current proceedings through an application filed on 4 May 2018. The applicant ultimately relied upon an amended application filed on 12 September 2019, from which he pressed the following sole ground:
Ground 3
The IAA erred when it did not properly consider whether it could consider the new Information.
Particulars
i.At paragraph 4 the IAA noted the applicant emailed a letter dated 10 August 2017 on 16 August 2017.
ii. At paragraph 5 the IAA dealt with the letter in the following way:
a.The IAA noted the applicant made claims he worked as a spy for the LTTE and that as a result the LTTE launched a successful attack on the SLA base at [redacted]; and as a result of which his life would be at risk if this knowledge became known;
b.The IAA noted the applicant did not previously provide this information because he felt he would be thought of negatively but he felt compelled to do so now;
c.The IAA observed that at no point had the applicant made this claim earlier, that he had been repeatedly asked by the delegate to provide full information about his claims for protection, and that he was repeatedly asked if he had given full and complete information. The applicant repeatedly answered in the affirmative;
d.The IAA noted the applicant was assisted at the SHEV interview by a registered migration agent who was also encouraged to provide complete information about his client's claims for protection.
e.At paragraph 5 the IAA did not accept the applicant's claim that he did not give the new information to the delegate because he was fearful of her reaction.
f.At paragraph 5 the IAA did not accept that the claim that the applicant also spied on the LTTE in 2006 is, in the circumstances, credible personal information which was not known previously and had it been known, may have affected the consideration of the applicant's claims. This was clearly a refence to S 473DD (b) (ii).
g.At paragraph 5 the IAA then immediately went on to find it was not satisfied that exceptional circumstances existed to justify its consideration. This was clearly a refence to S 473DD (a).
h.In not accepting the applicant's claim that he did not give the new information to the delegate because he was fearful of her reaction, the IAA failed to consider the reasons put forward by the applicant as to why he did not raise the claims earlier, to wit that he felt he would be thought of negatively but he felt compelled to do so now and also his life would be at risk if this knowledge became known.
i.In not accepting the applicant's claim that he also spied on the LTTE in 2006 is, in the circumstances, credible personal information which was not known previously and had it been known, may have affected the consideration of the applicant's claims, the IAA did not give any reasons and presumably relied upon the applicant's failure to make this claim earlier.
j.In expressing the conclusion at [5] that the IAA ‘was not satisfied that exceptional circumstances exist to justify its consideration’, the IAA did not consider the significance generally or the way in which the claims in the new information related to the earlier claims made by the applicant, thereby committing jurisdictional error.
k.Further, there the IAA had confined its consideration of whether there were exceptional circumstances to the evaluation of the applicant’s explanation for not having provided the information earlier, which indicated the IAA had unduly narrow interpretation of the term “exceptional circumstances”, amounting to a constructive failure by the IAA to exercise jurisdiction.
iii. The applicant refers to paragraph 6 of the decision, and states:
a.the IAA committed jurisdictional error in not considering an undated letter from [redacted] [(First Letter)], and in not being satisfied that the letter provides credible information which was not known and, had it been known, may have affected the consideration of the applicant's claims, and in not being satisfied that exceptional circumstances exist to justify its consideration, when the IAA had confined its consideration of whether there were exceptional circumstances to the evaluation of the appellant's explanation for not having provided the information earlier, which indicated the IAA had applied an unduly narrow interpretation of the term “exceptional circumstances”, thereby amounting to a constructive failure by the IAA to exercise jurisdiction.
b.Further, the IAA did not consider the significance generally or the way in which the claims in the new information related to the earlier claims made by the applicant, thereby committing jurisdictional error.
iv. The applicant refers to paragraph 7 of the decision, and states
a.the IAA committed jurisdictional error in not considering an undated letter from an unknown person titled “Confirming Lack of Safety” and in not being satisfied that the letter provides credible information which was not known and, had it been known, may have affected the consideration of the applicant's claims, and in not being satisfied that exceptional circumstances exist to justify its consideration, when the IAA had confined its consideration of whether there were exceptional circumstances to the evaluation of the appellant's explanation for not having provided the information earlier, which indicated the IAA had applied an unduly narrow interpretation of the term “exceptional circumstances”, thereby amounting to a constructive failure by the IAA to exercise jurisdiction.
b.Further, the IAA did not consider the significance generally or the way in which the claims in the new information related to the earlier claims made by the applicant, thereby committing jurisdictional error.
(As per the original)
Section 473DD of the Act provided:
Considering new information in exceptional circumstances
For the purposes of making a decision in relation to a fast track reviewable decision, the Immigration Assessment Authority must not consider any new information unless:
(a)the Authority is satisfied that there are exceptional circumstances to justify considering the new information; and
(b)the referred applicant satisfies the Authority that, in relation to any new information given, or proposed to be given, to the Authority by the referred applicant, the new information:
(i)was not, and could not have been, provided to the Minister before the Minister made the decision under section 65; or
(ii)is credible personal information which was not previously known and, had it been known, may have affected the consideration of the referred applicant's claims.
In AUS17 v Minister for Immigration and Border Protection [2020] HCA 37; (2020) 269 CLR 494 (AUS17), it was stated at [10]-[11] per Kiefel CJ, Gageler J (as his Honour was), Keane and Gordon JJ (footnotes omitted):
10.Section 473DD would be at war with itself, and the purpose of s 473DD(b)(ii) would be thwarted, if the circumstance that there was new information from a referred applicant meeting the description in either s 473DD(b)(i) or s 473DD(b)(ii) were able to be ignored by the Authority in assessing the existence of exceptional circumstances justifying consideration of that new information in order to meet the criterion specified in s 473DD(a).
11.Logic and policy therefore demand that the Authority assess such new information as it might obtain from the referred applicant first against the criteria specified in both s 473DD(b)(i) and s 473DD(b)(ii) and only then against the criterion specified in s 473DD(a). If neither of the criteria specified in s 473DD(b)(i) and s 473DD(b)(ii) is met, the Authority is prohibited from taking the new information into account in making its decision on the review. Further assessment of the new information against the criterion specified in s 473DD(a) is redundant. If either the criterion specified in s 473DD(b)(i) or the criterion specified in s 473DD(b)(ii) is met, that is a circumstance which must be factored into the subsequent assessment of whether the new information meets the criterion specified in s 473DD(a). If both the criterion specified in s 473DD(b)(i) and the criterion specified in s 473DD(b)(ii) are met, that too is a circumstance which must be factored into the subsequent assessment of whether the new information meets the criterion specified in s 473DD(a) and which must heighten the prospect of that criterion being met.
At [4] of its decision, the IAA recorded the new information before it. It reasoned as follows in relation to that information at [5]-[7] of its decision (some details have been redacted to prevent identification of the applicant):
5.In the letter from the applicant, he claimed that he worked as a spy for the Liberation Tigers of Tamil Eelam (LTTE) around 2006 and that as a result of his spying activity the LTTE was able to launch a successful attack on the Sri Lankan Army (SLA) base at [redacted]. The applicant claimed that the reason that he did not provide this information earlier was that many army soldiers had been killed because of his spying activities and he thought that he would be thought of negatively. He stated that he thought there would be problems if he disclosed the information earlier but felt compelled to now do so. The applicant previously claimed he assisted the LTTE as a young boy cleaning and greasing their weapons on a ‘Sea Tiger’ base on his father’s land and that he stood sentry on one occasion. At no point did he make the claim he is now advancing of also being a spy for the LTTE. The applicant is now suggesting that as a very small boy he spied on army camps, as a result of which many soldiers were killed, and that if the information about his spying became known, his life will be at risk. I have listened to the recording of the SHEV interview and note that the delegate repeatedly asked the applicant to provide full information about his claims for protection. The delegate repeatedly asked the applicant if he had given full and complete information and the applicant repeatedly answered in the affirmative. I note that the answers that the applicant provided to the delegate in the SHEV interview were, at times, lengthy and he repeatedly stated that he did not have any further information to provide. I also note that the applicant was assisted at the SHEV interview by a registered migration agent who was also encouraged to provide complete information about his client’s claims for protection. I do not accept the applicant’s claim that he did not give the new information to the delegate because he was fearful of her reaction. The delegate was aware of the applicant’s involvement with the LTTE in his youth and I do not accept that the claim that the applicant also spied for the LTTE in 2006 is, in the circumstances, credible personal information which was not known previously and had it been known, may have affected the consideration of the applicant’s claims. I am not satisfied that exceptional circumstances exist to justify its consideration.
6.The submission included a translation from Tamil of an undated letter from [redacted] who, the letter claims, was [redacted] (First Letter). The letter provides information about the applicant and gives some reasons why he did not attend school for a period of time, including the claim that officers of the Criminal Investigation Division (CID) made queries about the applicant along the roads he used to go to school, that the CID told people along the road that the applicant had to be arrested and that, on one occasion, there was an attempt made to abduct him. Given that the reasons why the applicant did not attend school were canvassed in the SHEV interview and that the applicant never claimed that there had been an attempt to abduct him on one occasion, I am not satisfied that the letter provides credible personal information which was not known previously and, had it been known, may have affected the consideration of the applicant’s claims. The letter refers to information in the past and there is no information before me to explain why the applicant could not have provided the letter to the delegate. I am not satisfied that exceptional circumstances exist to justify its consideration.
7.The submission included a translation from Tamil of an undated letter from an unknown person titled ‘Confirming Lack of Safety’. The letter states that the applicant’s parents travelled to [an area] due to the war in 2006, that they were supporters of the Tamil National Alliance (TNA), and because of this, and the location of an LTTE camp near their house, they were subject to threats from army intelligence. I note the applicant has not previously mentioned that his family were TNA supporters and that this contributed to the threats received. The provenance of the letter is unknown, it is not dated and it is of doubtful probative value. I am not satisfied that it provides credible personal information which was not known previously and, had it been known, may have affected the consideration of the applicant’s claims. The letter refers to information in the past and there is no information before me to explain why the applicant could not have provided the letter to the delegate. I am not satisfied that exceptional circumstances exist to justify its consideration.
Paragraph 5 – the new claim
The particulars to the ground suggested that the IAA failed to consider the reasons put forward by the applicant for why he had not raised the claim earlier. However, the IAA expressly considered the reasons given for not disclosing the claim earlier at [5]. The IAA did not find those reasons persuasive, for reasons given in that paragraph.
The applicant submitted that it was unreasonable or illogical for the IAA to have not accepted his explanation that he had not disclosed his new claim about spying for the LTTE earlier because he was worried there would be problems if he did so. The applicant submitted that the claim of spying and its consequences was a “far cry” from his other claims of involvement with the LTTE (which had included things like going to the base, greasing the guns, helping with the boats, guard duty, and generally menial tasks requested of him by the LTTE).
However, the IAA was not obliged to accept the applicant’s explanation for why he had not raised the claim earlier. The applicant’s willingness to disclose other assistance he had provided to the LTTE was capable of being regarded as a matter indicating against his claimed fear of disclosing other claims of involvement (different though they may have been). Although another decision maker might have reasoned differently, this is not sufficient to meet the high thresholds associated with grounds of unreasonableness or illogicality: see for example Minister for Immigration and Citizenship v SZMDS [2010] HCA 16; (2010) 240 CLR 611 at [131] per Crennan and Bell JJ.
The applicant next submitted that no other attempt was made by the IAA to disclose other reasons for the applicant to have delayed. This was submitted to reveal a “total failure” to consider the credibility of the new claims themselves. The applicant also submitted that in focussing on the possible opportunities he had to disclose the new claim earlier, the IAA adopted an unduly narrow approach to the construction of exceptional circumstances. In this regard, the applicant relied upon cases including DZU17 v Minister for Immigration and Border Protection [2019] FCCA 491 (DZU17) (Judge Driver) at [48]-[54] and BVZ16 v Minister for Immigration and Border Protection [2017] FCA 958; (2017) 254 FCR 221 (BVZ16) (White J).
At hearing, the parties acknowledged that there had been developments in the case law since those cases including, notably, AUS17. The applicant clarified that his essential complaint was that, by reference to AUS17, the IAA failed to consider s 473DD(b)(ii).
I am not persuaded that the IAA did so. Unlike in DZU17 and BVZ16, the IAA expressly rejected at [5] that the new claim was “credible personal information which was not known previously and had it been known, may have affected the consideration of the applicant’s claims”. I accept that the late raising of the claim informed this finding, as did the IAA’s non-acceptance of the credibility of the explanation that had been provided by the applicant. However, the applicant did not draw attention to any authority precluding such matters from informing the assessment under s 473DD(b)(ii). Cases such as AAQ18 v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 759 at [18(11)] and [33] (Burley J) are to the contrary.
It is apparent that the IAA was not only concerned that the applicant had not provided the information earlier, but also that he had repeatedly told the Delegate that he had provided full information in relation to his claims. This, together with the repeated prompting at interview, the nature of the claim (which claimed an involvement with the LTTE that was notably beyond what had been claimed previously) and the IAA’s rejection of the credibility of the applicant’s explanation informed the IAA’s non-acceptance that the information was “credible personal information” in the requisite sense. As stated above, the fact that another decision maker may have taken a different view is insufficient to demonstrate that this approach was closed to the IAA.
Having regard to the above, I am not persuaded that the IAA failed to consider or appreciate the significance of the new claim in the context of the whole of the material upon which the applicant relied. I accept the Minister’s submission that the IAA appreciated the significance of the new claim within context. The significance of the claim was a consideration (amongst others) that informed the IAA’s credibility assessment.
Paragraph 6 – the First Letter
In relation to the First Letter, the applicant similarly contended that the IAA confined its consideration of whether there were exceptional circumstances to evaluation of the applicant’s explanation for not having provided the information earlier. The applicant submitted that the IAA failed to consider whether the First Letter was credible personal information which was not previously known and, had it been known, may have affected the consideration of his claims. The applicant also contended that the IAA did not consider the significance generally of the information or the way in which the claims in the new information related to his earlier claims.
I do not accept that the IAA failed to consider the significance of the information nor its relationship to the applicant’s earlier claims. Part of the reason the IAA did not accept the information was “credible personal information” was that it contained claims, of the nature expressed, that were made by another person and had not been made by the applicant before the Delegate. This was despite the reasons why the applicant did not attend school having been canvassed at interview.
Having regard to the above, I also do not accept that the IAA impermissibly confined its consideration to evaluation of the applicant’s explanation for not having provided the information earlier. The IAA expressly found that it was not satisfied that the letter contained credible personal information which was not known previously and, had it been known, may have affected the consideration of the applicant’s claims. This was informed by the IAA’s consideration that the information, of the type described and provided from another source, did not match the claims that had been made by the applicant at interview despite the issue being canvassed. The IAA then considered that there was no information before it to explain why it could not have been provided to the Delegate, addressing s 473DD(b)(i).
This reasoning was logically available to the IAA and the applicant has not demonstrated how it could be said to have been legally unreasonable (as appeared to be suggested in the applicant’s written submissions). The applicant has also not demonstrated that the approach taken by the IAA adopted an unduly narrow interpretation of exceptional circumstances in so reasoning. In any event, the IAA was not persuaded that either of the criteria under s 473DD(b) had been met: see AUS17 at [11] per Kiefel CJ, Gageler (as his Honour then was) and Keane and Gordon JJ.
Paragraph 7 – the second letter (Second Letter)
In relation to the Second Letter, the applicant similarly contended that the IAA confined its consideration of whether there were exceptional circumstances to the evaluation of his explanation for not having provided the information earlier. This was said to indicate that the IAA applied an unduly narrow interpretation of the term “exceptional circumstances”. The applicant also contended that the IAA did not consider the significance generally or the way in which the claims in the new information related to his earlier claims.
I am not persuaded that the IAA either confined its assessment in the manner suggested or that it failed to consider the significance of the Second Letter or its relationship to the applicant’s earlier claims. The IAA expressly considered both criteria in s 473DD(b) before considering exceptional circumstances. The IAA’s finding that the information was not “credible personal information” in the requisite sense was informed by the nature of the information, the unknown nature of its provenance, the fact that it was undated and (as with the First Letter) the fact that it made claims that had not been made by the applicant before the Delegate. These matters were capable of informing the question of whether the Second Letter contained credible personal information. The IAA then considered that there was no information before it to explain why the letter could not have been provided to the Delegate.
The applicant has not demonstrated that this approach was closed to the IAA, nor how it could be considered legally unreasonable. The IAA addressed both criteria in s 473DD(b) and found that they could not be met. Informed by this analysis, the IAA then proceeded to consider s 473DD(a). No legally relevant error has been demonstrated in the approach taken by the IAA.
CONCLUSION
For the reasons given above, I am not persuaded that the applicant has demonstrated that the IAA’s decision was affected by jurisdictional error. The application before the Court must therefore be dismissed.
I will hear from the parties in relation to costs.
I certify that the preceding thirty-four (34) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Laing. Associate:
Dated: 14 January 2025
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