CJH17 v Minister for Immigration
[2019] FCCA 67
•1 February 2019
FEDERAL CIRCUIT COURT OF AUSTRALIA
| CJH17 v MINISTER FOR IMMIGRATION & ANOR | [2019] FCCA 67 |
| Catchwords: MIGRATION – Review of Immigration Assessment Authority decision – refusal of a protection visa – applicant claiming a fear of harm in Iraq – applicant’s claims disbelieved in part and other fears found not to be well-founded – whether the Authority overlooked part of the applicant’s claims, misapplied the law or overlooked significant evidence considered – no jurisdictional error. |
| Legislation: Migration Act 1958 (Cth), ss.5H, 473CB, 473DD, 477 |
| Cases cited: Chan v Minister for Immigration (1989) 169 CLR 379 |
| Applicant: | CJH17 |
| First Respondent: | MINISTER FOR IMMIGRATION & BORDER PROTECTION |
| Second Respondent: | IMMIGRATION ASSESSMENT AUTHORITY |
| File Number: | SYG 1703 of 2017 |
| Judgment of: | Judge Driver |
| Hearing date: | Decided without oral hearing |
| Delivered at: | Sydney |
| Delivered on: | 1 February 2019 |
REPRESENTATION
| Counsel for the Applicant: | Mr B Zipser |
| Solicitors for the Applicant: | Stamford Law |
| Solicitors for the Respondents: | Mr J Pinder of Minter Ellison |
ORDERS
The application as amended on 26 September 2018 is dismissed.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT SYDNEY |
SYG 1703 of 2017
| CJH17 |
Applicant
And
| MINISTER FOR IMMIGRATION & BORDER PROTECTION |
First Respondent
| IMMIGRATION ASSESSMENT AUTHORITY |
Second Respondent
REASONS FOR JUDGMENT
Introduction and background
The applicant seeks judicial review of a decision of the Immigration Assessment Authority (Authority) made on 18 December 2015. The Authority affirmed a decision of a delegate of the Minister (delegate) not to grant the applicant a protection visa.
The following statement of background facts is derived from the submissions of the parties.
The applicant is a citizen of Iraq, who arrived in Australia at Christmas Island on 13 October 2012 and is an unauthorised maritime arrival.[1] He participated in an entry interview on Christmas Island on 22 October 2012.[2] Between October and December 2012 the applicant was in detention centres, following which he was granted a temporary visa and released into the community on the Australian mainland.[3]
[1] Court Book (CB) 127
[2] CB 1-18
[3] CB 49
On 19 May 2015 the applicant was invited to make a valid application for a specified visa.[4] The applicant subsequently applied for a temporary protection visa on 22 June 2015, via his appointed migration agent.[5]
[4] CB 19-24
[5] CB 25-86
The applicant attended an interview with the Minister’s Department on 7 October 2015.[6]
[6] CB 103-111
On 18 November 2015 the delegate refused to grant the applicant a temporary protection visa.[7] The delegate's decision was a fast track reviewable decision and was referred by the Minister to the Authority for review on 20 November 2015.[8] The Authority received a written submission from the applicant's migration agent on 15 December 2015.[9]
[7] CB 126-153
[8] CB 155-166
[9] CB 169-174
On 18 December 2015, the Authority affirmed the delegate's decision.[10]
[10] CB 180-192
Applicant’s claims
The applicant claimed to be a Shia Muslim who lived in Najaf from 2000 until 2012 when he departed Iraq. He claimed to have been a member of the Iraqi Army from 2006 until his departure and to fear harm in Iraq from the Mehdi Army (a Shia militia group) who had threatened him in the past. In support of his claimed fear of harm, the applicant gave the following account of events:
a)the applicant worked with the American forces, arresting terrorists and militia members (including members of the Mehdi Army) as part of his job with the Iraqi Army;
b)he was very secretive about his work with the American forces and even his closest friends did not know about it;
c)in 2009, the applicant was driving in his car with a friend, who was a supporter of the Mehdi Army;
d)without the applicant's knowledge, this friend took a USB from the applicant's car that contained photos and videos of the applicant assisting the American forces;
e)a few days later, the applicant's mother was questioned by members of the Mehdi Army about the applicant's whereabouts and his involvement with American forces;
f)the Mehdi Army subsequently threatened the life of the applicant and his family, unless he stopped working with the American forces; and
g)the Mehdi Army killed the applicant's brother in 2009.
Authority decision
Information considered
The Authority considered material referred by the Secretary under s.473CB of the Migration Act 1958 (Cth) (Migration Act).[11]
[11] CB 181 at [7]
In relation to a submission received from applicant's migration agent on 15 December 2015, the Authority noted that it “largely addresses the delegate's decision”, but also contained “new information”, which related to his claim to face the death penalty under Article 28(3) of Iraq's Military Penal Code because he took some photos and videos of the battles in which he took part. The new information was considered by the Authority under s.473DD because it was satisfied that the information was not and could not have been provided to the delegate and there were exceptional circumstances that justified considering it.[12]
Factual findings
[12] CB 181 at [7]; CB 184-185 at [18]
The Authority accepted the applicant was a Shia Muslim who served in the Iraqi Army as a non-commissioned officer of a rank equivalent to corporal from 2006 to 2012. It also accepted that during his service he was involved in “commando-type duties” in conducting joint raids with American troops on militants including the Mehdi Army.[13]
[13] CB 183 at [10]–[13]
However, the Authority did not accept that the applicant's claim to have been targeted by the Mehdi Army in 2009 was credible because his account of how they obtained the photo and video files “lack[ed] credibility”, he did not mention the incident in his entry interview, and he remained in Iraq and engaged in his normal activities for a further three years after the alleged threats began. Although the Authority accepted at “face value” that the applicant's brother was killed in 2009, it did not accept that the circumstances of his death involved the Mehdi Army or had any connection to the applicant.[14]
[14] CB 183-184 at [14]–[16]
The Authority found that the applicant was not formally discharged and had therefore deserted the Iraqi Army in 2012.[15]
Refugee criterion
[15] at [17]
Noting its finding that the applicant is of no interest to the Mehdi Army and having regard to country information, the Authority found that he would not face a real chance of persecution from the Mehdi Army.[16]
[16] CB 185 at [21]
The Authority accepted that “as a matter of law” the death penalty may be a possible punishment for desertion of the Iraqi Army. However, it found on the basis of country information that there is not a real chance that this punishment would be imposed now or in the foreseeable future. The Authority concluded that the applicant would not face a real chance of persecution due to his status as an Iraqi Army deserter.[17] Further, the Authority found that the applicant's actions in taking photos of himself dressed in military fatigues and standing informally alongside American military personnel do not engage Article 28(3) of Iraq's Military Penal Code. The Authority found that the photographs do not reveal any classified information that would be of concern to the Iraqi government and there was no evidence that the applicant had disseminated them or other military information (apart from providing them as part of his protection visa application, which was confidential).[18]
[17] CB 186 at [22]
[18] CB 186 at [24]
Having regard to the applicant's circumstances and the relevant country information regarding the security situation in Najaf, the Authority was not satisfied that the applicant would face a real chance of serious harm from militant groups including Daesh and other Sunni militia groups on return to his home area. The Authority found that there would be no impediment to the applicant returning to Najaf via Basra airport, noting that the areas the applicant would pass through are predominantly Shia populated areas that have favourable levels of security and remain under government control.[19]
[19] CB 186-187 at [25]–[28]
Upon consideration of the applicant's claims individually and cumulatively, the Authority found that the applicant did not have a well-founded fear of persecution and concluded he did not meet the requirements of the definition of refugee in s.5H(1) of the Migration Act.[20]
Complementary protection criterion
[20] CB 187 at [29]–[30]
For the same reasons, the Authority concluded that the applicant did not meet the complementary protection criterion.[21]
[21] CB 187-188 at [31]–[35]
The present proceedings
These proceedings began with a show cause application lodged on 29 May 2017 and filed on 2 June 2017. That application was filed several years outside the period prescribed in s.477(1) of the Migration Act and the applicant sought an extension of time under s.477(2). The applicant filed an amended application on 26 September 2018 in which he advanced grounds for an extension of time and raised the following grounds of review:
1. The Immigration Assessment Authority (“the IAA”), in its decision at [25]-[27], considered whether the applicant faced a real chance of harm “from Sunni groups because he is a Shia and a former soldier who supported military action”. The IAA concluded that “the applicant would not face a real chance of serious harm from militant groups including Daesh and other Sunni militia groups on return to Najaf”. The IAA fell into jurisdictional error in making this finding for the following reasons:
a) The IAA accepted (at [13]) that the applicant had been involved in raids on Sunni militia groups while in the Iraqi Army. The fact that the applicant was involved in such raids raises his profile in relation to attacks by Sunni militia groups should he return to Iraq. The IAA did not, in its decision at [25]-[27], have regard to this aspect of the applicant’s profile. The IAA thereby overlooked an integer of the applicant’s claims.
b) The IAA accepted country information that there were “low levels of violence” in the southern governorates. A “low level of violence” satisfies the “real chance” threshold. In light of the country information, the IAA misapplied the law in finding that the applicant would not face a real chance of serious harm.
2. The IAA found in it decision at [15] that “the applicant has not been threatened by the Mehdi Army as he claims and that a USB storage device … containing images of the applicant conducting raids against militant groups was not taken from him by a Mehdi Army supporter”.
One reason the IAA made this finding was because of its intermediate finding at [15] that “the fact that the applicant went about his ordinary activities between 2009 and 2012 is strong evidence that he has not been threatened by and is not of active interest to a Shia militia like the Mehdi Army”. The IAA, in making this intermediate finding, overlooked the applicant’s evidence given at the protection visa interview that, while he worked at the army bases, the militants “would not have been able to kill him”: see CB 137 [70]. To overlook significant evidence is a jurisdictional error.
At an interlocutory hearing on 22 November 2018, I granted the extension of time sought under s.477(2) of the Migration Act, made orders for the filing of additional material and listed the matter for a final hearing in February 2019. The parties indicated at that time that they may not require an oral hearing. This was confirmed in correspondence on 14 January 2019.
Nothing further was filed under my procedural orders. At the extension of time hearing, I received as evidence the court book filed on 17 July 2017 and the applicant’s affidavit made on 11 May 2017 which supported the granting of an extension of time.
The applicant and the Minister both filed pre-hearing written submissions and made oral submissions through their counsel at the interlocutory hearing.
Consideration
Applicant’s contentions
Ground 1 – error in application of real chance test
The Authority accepted the applicant’s claims that he was a Shia Muslim[22] who “served in the Iraqi Army 10th Division and then transferred to the Iraqi Army 8th Division in 2007”.[23] The Authority also accepted that the applicant was from the city of Najaf in southern Iraq.[24]
[22] at [10]
[23] at [11]
[24] at [25]
The Authority[25] considered whether the applicant’s profile as “a Shia and a former soldier who supported US military action”, “would give rise to a claim for protection in relation to his former place of residence in Najaf”.[26]
[25] at [25]-[27]
[26] at [25]
The Authority concluded at [27]:
After having regard to the information above regarding the security situation in Najaf, I am satisfied that the applicant would not face a real chance of serious harm from militant groups, including Daesh and other Sunni militia groups on return to Najaf.
The applicant contends that the Authority fell into jurisdictional error in making this finding for the following reasons.
First, the Authority accepted[27] that the applicant had been involved in raids on Sunni militia groups while in the Iraqi Army. Specifically, it found:
The applicant claims his military duties in the Iraqi army involved commando type activities conducting joint raids with American troops targeting members of militias, Al Qaeda and the Mehdi Army … I find that he was involved in commando-type duties conducting joint raids with US troops on militants, including the Mehdi Army.
[27] at [13]
The reference to “militants” in the last sentence at [13] includes Sunni militant groups such as Al Qaeda and Daesh.
The fact that the applicant was involved in such raids is said to raise his profile in relation to attacks by Sunni militia groups should he return to Iraq.
The Authority did not, in its decision at [25]-[27], refer to this aspect of the applicant’s profile. Specifically:
a)the Authority stated:[28]
While the applicant has not raised any specific claim to fear harm from Sunni groups because he is a Shia and a former soldier who supported US military action, I have considered whether this would give rise to a claim for protection in relation to his former place of residence in Najaf.
The word “this” is said to refer to the applicant’s profile as a Shia and a former soldier who supported US military action. However, an additional aspect of the applicant’s profile was that, as the applicant claimed and the Authority accepted at [13], he was involved in joint raids with US troops on militants, including Sunni militants. This would, in the applicant’s submission, raise the applicant’s profile in the eyes of Sunni militants; and
b)no other part of the Authority’s reasons at [25]-[27] refers to or takes into account the additional aspect of the applicant’s profile as a soldier involved in joint raids with US troops on militants, including Sunni militants.
[28] at [25]
The applicant contends that the Authority thereby overlooked an integer of his claims which clearly arose on the materials before it. This is said to be a jurisdictional error, as found in NABE v Minister for Immigration(No.2)[29] where the Full Federal Court stated:
[29] (2004) 144 FCR 1 at [55]-[63]
… Where the Tribunal fails to make a finding on “… a substantial, clearly articulated argument relying upon established facts” that failure can amount to a failure to accord procedural fairness and a constructive failure to exercise jurisdiction …
…
The review process is inquisitorial rather than adversarial. The Tribunal is required to deal with the case raised by the material or evidence before it: …. There is authority for the proposition that the Tribunal is not to limit its determination to the “case” articulated by an applicant if evidence and material which it accepts raise a case not articulated … It has been suggested that the unarticulated claim must be raised “squarely” on the material available to the Tribunal before it has a statutory duty to consider it: SDAQ v Minister for Immigration and Multicultural and Indigenous Affairs (2003) 129 FCR 137 ; 199 ALR 265 ; [2003] FCAFC 120 at [19] per Cooper J. The use of the adverb “squarely” does not convey any precise standard but it indicates that a claim not expressly advanced will attract the review obligation of the Tribunal when it is apparent on the face of the material before the Tribunal …
… It is plain enough, in the light of Dranichnikov, that a failure by the Tribunal to deal with a claim raised by the evidence and the contentions before it which, if resolved in one way, would or could be dispositive of the review, can constitute a failure of procedural fairness or a failure to conduct the review required by the Act and thereby a jurisdictional error.
Secondly, the Authority accepted country information that there were “low levels of violence” in the southern governorates. A “low level of violence” satisfies the “real chance” threshold. For example, in Chan v Minister for Immigration[30] members of the High Court commented in relation to the meaning of “well-founded fear”. Mason CJ stated at 389:
I agree with the conclusion reached by McHugh J that a fear of persecution is “well-founded” if there is a real chance that the refugee will be persecuted if he returns to his country of nationality … I prefer the expression “a real chance” because it clearly conveys the notion of a substantial, as distinct from a remote chance, of persecution occurring and because it is an expression which has been explained and applied in Australia: see the discussion in Boughey v R 161 CLR 10 at 21, per Mason, Wilson and Deane JJ.
[30] (1989) 169 CLR 379
McHugh J stated at 429:
a fear may be well-founded for the purpose of the Convention and Protocol even though persecution is unlikely to occur … an applicant for refugee status may have a well-founded fear of persecution even though there is only a 10 per cent chance that he will be shot, tortured or otherwise persecuted. Obviously, a far-fetched possibility of persecution must be excluded. But if there is a real chance that the applicant will be persecuted, his fear should be characterised as “well-founded” for the purpose of the Convention and Protocol.
In Minister for Immigration v Guo[31] six members of the High Court (including Dawson J) stated the following in relation to the meaning of “well-founded fear”:
Chan is an important decision of this court because it establishes that a person can have a well-founded fear of persecution even though the possibility of the persecution occurring is well below 50 per cent. But to use the real chance test as a substitute for the Convention term “well-founded fear” is to invite error ... Nevertheless, it is always dangerous to treat a particular word or phrase as synonymous with a statutory term, no matter how helpful the use of that word or phrase may be in understanding the statutory term ... A fear is “well-founded” when there is a real substantial basis for it. As Chan shows, a substantial basis for a fear may exist even though there is far less than a 50 per cent chance that the object of the fear will eventuate. But no fear can be well-founded for the purpose of the Convention unless the evidence indicates a real ground for believing that the applicant for refugee status is at risk of persecution. A fear of persecution is not well-founded if it is merely assumed or if it is mere speculation.
[31] (1997) 191 CLR 559 at 572
In light of the country information, the applicant contends that the Authority misapplied the law in finding that the applicant would not face a real chance of serious harm.
Ground 2 – overlooking evidence
As recorded by the Authority at [14]:
The applicant claims he was targeted by the Mehdi Army in 2009 because they had obtained digital photographs and video recordings of him accompanying US troops while conducting raids on militants.
The Authority considered this claim at [14] and [15] and concluded at [15]:
the applicant has not been threatened by the Mehdi Army as he claims and that a USB storage device ... containing images of the applicant conducting raids against militant groups was not taken from him by a Mehdi Army supporter.
One reason the Authority made this finding was because of its intermediate finding at [15] that “the fact that the applicant went about his ordinary activities between 2009 and 2012 is strong evidence that he has not been threatened by, and is not of active interest to, a Shia militia like the Mehdi Army”.
The applicant served in the Iraqi Army from 2006 to some time in 2012.[32] The applicant gave evidence at the temporary protection visa interview that “at the [army] base [the Mehdi Army] would not have been able to kill him”.[33] The applicant submits that this evidence, if accepted by the Authority, would provide a satisfactory explanation as to how the applicant could go about his ordinary activities between 2009 and 2012 while being of interest to the Mehdi Army at the same time.
[32] see CB 134 at [51] and [60]
[33] CB 137 at [70]
The applicant’s complaint is that the Authority appears to have overlooked this evidence in making the intermediate finding referred to at [38] above. In relation to whether the Authority overlooked evidence:
a)on the one hand, the Authority is not required to refer in its reasons to all evidence before it, and the fact the Authority has not referred to an item of evidence does not require a conclusion that the Authority overlooked the evidence. Further, even if the Authority overlooks peripheral evidence, this would not be a jurisdictional error; but
b)on the other hand, where a decision-maker overlooks important evidence concerning a material issue, this may be a jurisdictional error. See for example:
i)VAAD v Minister for Immigration[34] where “the Tribunal failed to consider a document, the UNP Letter, which was … arguably of critical importance to the claims of all the appellants …”;
ii)WAFP v Minister for Immigration[35] where “The failure by the RRT to refer to the interview … and to take it into account … did amount to an error of law, because it constituted a failure to have regard to relevant material, which is so fundamental that it goes to jurisdiction.”; and
iii)Minister for Immigration v SZRKT[36] where Robertson J stated:
The relevance of the Punjab University transcript to the question of the nature of the applicant’s study at that university was so high that the obvious inference that the absence of reference to the document, either by putting its falsity to the applicant or by seeking an explanation of how his evidence should or could be reconciled with the transcript, supported the conclusion that the Tribunal did not take it into account is not outweighed by general references to material on the files. This is a matter of ordinary fact-finding rather than depending on some special tenet of administrative law. Neither, in my opinion, is it outweighed by a general statement by the Tribunal that it had a range of documents about the circumstances of the applicant.
[34] [2005] FCAFC 117 at [77]
[35] [2003] FCAFC 319 at [21]
[36] (2013) 212 FCR 99 at [72]
In the present case, the applicant submits that the Court should conclude that the Authority overlooked important evidence concerning a material issue, being the evidence the applicant gave at the temporary protection visa interview referred to at [36] above. If the Court agrees, this is a jurisdictional error.
Minister’s contentions
Ground 1
Ground 1 of the amended application alleges that the Authority erred at [25]-[27]. In those paragraphs, the Authority considered the security situation in Najaf and whether the applicant faced harm from Sunni groups because he was a Shia and a former soldier who supported US military action. The Authority was not satisfied that the applicant would face a real chance of serious harm from militant groups, including Daesh and other Sunni militia groups on return to Najaf.
The applicant alleges in the first aspect of this ground that in making this finding, the Authority did not consider its earlier finding at [13], that the applicant had been involved in raids on militants groups while a member of the Iraqi Army. However, the Authority’s decision must be read fairly and as a whole. It is said to be abundantly clear that, in making its findings at [25]-[27], the Authority was considering whether the applicant would face any harm as a Shia and former soldier who supported US military action. The Authority had expressly found, at [13], that the applicant's military service included raids on militias with US forces. It further accepted, at [15], that a soldier such as the applicant would have been viewed aversely by the militants. There is no basis to conclude that the Authority failed to take into account its finding regarding the applicant's service in reaching the conclusions at [25]-[27]. Further, at [29], the Authority stated it had considered the applicant’s claims cumulatively. In these circumstances, there is no basis to find that the Authority failed to consider any claim.
The second aspect to this ground contends that the Authority's citation of country information stating that there is a low level of violence in southern governorates is sufficient to satisfy the real chance threshold of a risk of harm. The Minister submits that, rather than amounting to a misapplication of the law as contended by the applicant, this is an attempt to engage the Court in impermissible merits review. The Authority did not misunderstand or misapply the law in making its finding that there was not a real chance of serious harm in Najaf.
Ground 2
Ground 2 alleges that the Authority, in rejecting the applicant’s claims to have been threatened by the Mehdi Army and to have had his USB device taken by a supporter of the Mehdi Army,[37] failed to consider an aspect of the applicant’s oral evidence.
[37] at [15]
In making its finding at [15], the Authority did not expressly refer to the applicant’s oral evidence to the effect that militants would not have been able to kill him while he was at the base. However, as is acknowledged by the applicant, the Authority is not obliged to refer to each and every aspect of the evidence before it, and the fact that the Authority has not referred to an aspect of evidence does not necessitate a conclusion that it overlooked the evidence. It is for the applicant to establish that the evidence has been overlooked. The Minister submits that in the circumstances of this case, it should not be inferred that the Authority did overlook or fail to consider this matter.
The Minister further submits that, in any event, the applicant’s oral evidence did not directly address the Authority’s concern, at [15], which was that despite claiming that the Mehdi Army knew where he worked, the applicant remained in Iraq for three years and engaged in his normal activities despite claiming to fear harm from specified threats from 2009 onwards. Even if the applicant's oral evidence was overlooked, the Minister submits that this would not establish any jurisdictional error when regard is had to the lack of cogency of the evidence and its potential relevance to the Authority’s reasoning.[38]
[38] cf SZRKT
Resolution
While the grounds in the amended application are arguable, and supported the granting of an extension of time, I am not persuaded that the Authority fell into jurisdictional error.
In relation to Ground 1, the Authority referred to the applicant’s claims at [13]:[39]
The applicant claims his military duties in the Iraqi army involved commando-type activities conducting join raids with American troops targeting members of militias, Al Qaeda and the Mehdi Army. At interview he described his duties as “getting information from intelligence and joining the Americans raiding and storming to stop militias”. He described weapons training in the use of M-16 and AK-47 assault rifles and stated that as part of a commando unit, he received better pay than ordinary soldiers. The Iraqi Army’s 10th Division and 8th Division both contained commando units[40] that would have engaged in the types of activities described by the applicant. I have found previously that the applicant served in the Iraqi Army’s 10th Division and 8th Division and after considering his statements regarding weapons training and higher pay, which is consistent with the country information, I find that he was involved in commando-type duties conducting joint raids with US troops on militants, including the Mehdi Army.
[39] CB 183
[40] “Iraqi Security Forces Order of Battle (OOB)”, The Long War Journal, 30 April 2009, 01 January 2011, CIS20127
The Authority plainly was aware of the applicant’s claim to engage in military activities against Sunni militants.
The Authority’s factual finding at [11] is also material to its consideration of the applicant’s claims.
In my view, there is, consistently with the Minister’s submissions, no ambiguity in the Authority’s conclusions concerning the applicant’s claims at [25]-[27]. The Authority’s conclusion at [27][41] specifically dealt with the applicant’s risk of harm from Sunni militant groups.
[41] CB 187
The Authority at [26] specifically noted independent country information that the risk of hostile militant attacks within Najaf was “negligible”. There was, in my view, no misapplication of the real chance test in this case.
In relation to Ground 2, the applicant’s circumstances on and off the military base were recounted by the delegate in his decision at [68]-[70].[42] It is plain that the applicant’s fears of harm related to time he spent off the military base and that he claimed he was at risk of harm outside the base. In my view, the Authority’s consideration of the applicant’s claim should be considered in that context and that his “normal activities” should be seen as those conducted off the military base. It was open to the Authority to conclude, as it apparently did, that the militants feared by the applicant had ample opportunity to harm him while he was off the base, and had not done so.
[42] CB 136-137
Conclusion
The applicant is unable to demonstrate that the decision of the Authority is affected by any jurisdictional error. The decision is therefore a privative clause decision and the application must be dismissed. I will so order.
I will hear the parties as to costs.
I certify that the preceding fifty-six (56) paragraphs are a true copy of the reasons for judgment of Judge Driver
Associate:
Date: 1 February 2019
Key Legal Topics
Areas of Law
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Administrative Law
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Immigration
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Statutory Interpretation
Legal Concepts
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Judicial Review
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Jurisdiction
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Natural Justice
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Procedural Fairness
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Statutory Construction
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