HIGH COURT OF AUSTRALIA
KIEFEL CJ,
KEANE, GORDON, EDELMAN AND STEWARD JJDQU16 & ORS APPELLANTS
AND
MINISTER FOR HOME AFFAIRS & ANOR RESPONDENTS
DQU16 v Minister for Home Affairs
[2021] HCA 10
Date of Hearing: 4 February 2021
Date of Judgment: 7 April 2021S169/2020
ORDER
Appeal dismissed with costs.
On appeal from the Federal Court of Australia
Representation
C A Webster SC with I J King and E C Graham for the appellants (instructed by Clifford Chance)
A M Mitchelmore SC with G J Johnson for the first respondent (instructed by Australian Government Solicitor)
Submitting appearance for the second respondent
Notice: This copy of the Court's Reasons for Judgment is subject to formal revision prior to publication in the Commonwealth Law Reports.
KIEFEL CJ, KEANE, GORDON, EDELMAN AND STEWARD JJ. Section 36(2) of the Migration Act1958 (Cth) relevantly provides two criteria for the grant of a protection visa: that the applicant is a non‑citizen in Australia "in respect of whom the Minister is satisfied Australia has protection obligations because the person is a refugee" under s 36(2)(a); and, if the applicant does not satisfy that criterion, that the applicant meets the complementary protection criterion under s 36(2)(aa), which gives effect to some of Australia's non‑refoulement obligations under international instruments.
The first appellant, an Iraqi national, sought a protection visa relying on s 36(2)(a) and s 36(2)(aa) of the Migration Act. The first appellant said he feared persecution[1], and would suffer significant harm[2], if returned to Iraq because, while in Iraq, he sold alcohol, which is banned by local law in some parts of Iraq and considered "immoral" and "un-Islamic" by Sunni and Shi'ite extremists. The claims of the second and third appellants, the first appellant's wife and child, depended on the claims of the first appellant. The Immigration Assessment Authority ("the Authority") found that the first appellant had not been personally targeted for reasons relating to the sale of alcohol, that he did not face a real risk of harm if returned to Iraq because he had sold alcohol previously, and, critically for this appeal, that if the first appellant returned to Iraq he would not continue to sell alcohol. The Authority affirmed the decision of the delegate of the then Minister for Immigration and Border Protection[3] ("the Minister") not to grant the appellants protection visas. The Authority's approach to, and determination of, the first appellant's claim under s 36(2)(a) was not in issue in this Court.
[1]Migration Act, s 36(2)(a).
[2]Migration Act, s 36(2)(aa).
[3]Now the Minister for Home Affairs.
This Court held in Appellant S395/2002 v Minister for Immigration and Multicultural Affairs[4] that, in assessing the refugee criterion in s 36(2)(a), an asylum seeker cannot be expected to hide or change behaviour that is the manifestation of a protected characteristic under the Convention relating to the Status of Refugees as modified by the Protocol relating to the Status of Refugees ("the Convention") in order to avoid persecution[5]. Appellant S395
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- Case
- [2021] HCA 10
- Decision Date
CaseChat Overview and Summary
The central legal issue before the High Court was whether the Authority's failure to consider the principle established in *Appellant S395/2002 v Minister for Immigration and Multicultural Affairs* (2003) 216 CLR 473, which held that an asylum seeker cannot be expected to hide or change behaviour manifesting a protected characteristic for the purposes of assessing a claim under s 36(2)(a), constituted a jurisdictional error when assessing the complementary protection criterion under s 36(2)(aa). The complementary protection criterion requires an assessment of whether "significant harm" is a "necessary and foreseeable consequence" of the applicant's return to their receiving country.
The High Court held that while the statutory questions posed by s 36(2)(a) and s 36(2)(aa) are distinct, a decision-maker assessing the complementary protection criterion under s 36(2)(aa) is entitled to refer to and rely on relevant findings made when considering the refugee criterion under s 36(2)(a), particularly where the factual bases overlap. The Court found that the question under s 36(2)(aa) is whether, in light of all relevant findings, there is a real risk of significant harm as a necessary and foreseeable consequence of the non-citizen's removal. The Court concluded that the Authority had indeed conducted this assessment in the present case.
The appeal was dismissed with costs.
Orders
Orders of the court
Appeal dismissed with costs.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
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Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
Established by: KIEFEL CJ, KEANE, GORDON, EDELMAN AND STEWARD JJ
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