EDM16 v Minister for Immigration
[2018] FCCA 419
•23 February 2018
FEDERAL CIRCUIT COURT OF AUSTRALIA
| EDM16 v MINISTER FOR IMMIGRATION & ANOR | [2018] FCCA 419 |
| Catchwords: MIGRATION – Review of decision of AAT to dismiss application for protection under the provisions of the Migration Act 1958 – no appearance by applicant in response to invitation to appear before AAT pursuant to section 425 – application dismissed but applicant advised of right to apply for reinstatement – applicant failed to apply for reinstatement – application finally dismissed – jurisdiction error – no legal or procedural fairness found – application dismissed. |
| Legislation: Migration Act 1958 (Cth), ss.425; 426A; 426B; 430A; 441A; 441C Migration Regulations 1994, r.4.35D(3) Migration Regulations 1994, r: 4.35D(3) Migration Regulations 1994 |
| Cases cited: Minister for Immigration & Border Protection v Singh (2014) 231 FCR 437 Kaur v Minister for Immigration & Border Protection (2014) 236 FCR 393 MZALO v Minister for Immigration & Border Protection [2016] FCA 1339 |
| Applicant: | EDM16 |
| Respondent: | MINISTER FOR IMMIGRATION & BORDER PROTECTION |
| Second Respondent: | ADMINISTRATIVE APPEALS TRIBUNAL |
| File Number: | ADG 445 of 2016 |
| Judgment of: | Judge Brown |
| Hearing date: | 2 February 2018 |
| Date of Last Submission: | 2 February 2018 |
| Delivered at: | Adelaide |
| Delivered on: | 23 February 2018 |
REPRESENTATION
| Counsel for the Applicant: | In person |
| Counsel for the Respondent: | Ms Stokes |
| Solicitors for the First Respondent: | Australian Government Solicitor |
| Counsel for the Second Respondent: | Submitting appearance |
ORDERS
The application filed 28 December 2016 is dismissed.
The applicant pay the first respondent’s costs fixed in the sum of $4,000.00.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT ADELAIDE |
ADG 445 of 2016
| EDM16 |
Applicant
And
| MINISTER FOR IMMIGRATION & BORDER PROTECTION |
Respondent
| ADMINSTRATIVE APPEALS TRIBUNAL |
Respondent
REASONS FOR JUDGMENT
Introduction
This is an application for judicial review of a decision of the Administrative Appeals Tribunal “the AAT”, made on 12 December 2016. The decision confirmed an earlier decision of a delegate of the Minister for Immigration & Border Protection[1] not to grant the applicant a protection visa pursuant to the provisions of the Migration Act 1958 “the Act”.
[1] As the Minister for Home Affairs was previously known
The application turns on the provisions of the Act dealing with applicants who fail to respond to an invitation, issued by the AAT, to give evidence in support of their claim for protection and further provisions, which authorise the Tribunal to dismiss application for administrative review, in circumstances where the applicant concerned has failed to apply for a reinstatement of the relevant application.
It is not the function of this court to determine the applicant’s claim for protection or assess any evidence relevant to that claim, given the dismissal of the claim. Rather, the task for the court is to examine whether the AAT correctly applied the legislative provisions applicable to the applicant’s non-appearance and properly exercise the jurisdiction conferred upon it to dismiss her application.
Background
The applicant is a citizen of Malaysia. She applied for the relevant visa on 10 December 2014. In a statement filed in support of her application, she claimed that she had become involved with a drug trafficker, through her legitimate work in Malaysia. She claimed that this person believed that she had informed upon him, to the Malaysian Police, leading to his arrest and the confiscation of a quantity of illicit drugs.
The applicant further claimed that associates of this person had subsequently threatened her and demanded payment of a significant sum of money, equivalent to the value of the drugs confiscated. She further claimed that the Malaysian authorities were not willing to investigate her case and she was therefore at risk of suffering significant harm, from these criminal elements, if returned to Malaysia. On this basis, she sought the protection of Australia.
On 6 August 2015, the applicant was invited to attend an interview, scheduled to take place on 11 September 2015. She was further advised that an interpreter would be provided to assist her during the relevant interview with the Ministerial delegate. The invitation in question was forwarded to the applicant, via an email address, which the applicant had provided.
The letter in question contained the following statement:
“If you are unable to attend this interview you should contact us as soon as possible using the contact details below. You may be required to provide evidence as to why you cannot attend the interview. A rescheduled interview date may not be offered.
If you do not attend an interview your application will be decided on the information already provided to us.”[2]
[2] See casebook at page 58
The applicant did not attend the interview scheduled for her. The delegate in question nonetheless contacted her by telephone via a number provided in her application. During a conversation with her conducted through an interpreter who had been arranged to assist the applicant, the delegate was informed that the applicant had not attended because she had been unwell. However, when asked if there was any evidence available to support this assertion, particularly in the form of some medical evidence, the applicant indicated that there was not.
Notwithstanding this omission, the applicant was given an opportunity, by the delegate, to provide further information within seven days.[3] No such evidence was forthcoming and, as a consequence, the delegate concluded that the applicant had had a reasonable opportunity to provide further oral evidence in support of her claim and it was therefore open to the delegate to assess the case on the basis of the evidence currently available.
[3] Ibid at page 68
The delegate considered that there was a lack of detail in the applicant’s claim for protection and a dearth of supporting evidence. It was also noted that there had been a delay in lodging the protection application, following the applicant’s initial arrival in Australia. As a consequence, the delegate did not find the applicant’s claim for protection to be credible and, in objective terms, there was no real chance of her suffering persecution, if returned to Malaysia.
The application for review to the AAT
On 7 October 2015, the applicant applied to the AAT for a review of this decision. The following day, the Tribunal acknowledged receipt of the application, in writing, by means of a letter forwarded to the applicant via her email address, which had been supplied with the application.
In this letter, the applicant was reminded of the importance of informing the Tribunal, if she changed any of her contact details, including her mailing address, email address or any other electronic contact details.
Pursuant to section 425 of the Act, the Tribunal is obligated to invite any applicant seeking review of a protection visa decision to attend before it for the purpose of advancing arguments and presenting evidence in support of the application concerned.
As a consequence of this requirement, on 17 August 2016, the AAT invited the applicant to attend a hearing, which was scheduled for 25 November 2016. In the relevant invitation letter, it was envisaged that the applicant would be able to give evidence and present arguments relating to the issues arising in [her] case at this hearing.
The Tribunal record indicates that the applicant did not attend this hearing. In addition, the record indicates that on 8 October 2015, 18 November 2016 and 24 November 2016, SMS messages were sent to the applicant’s mobile telephone number reminding her of the hearing date.
On 25 November 2016, the Tribunal wrote to the applicant indicating that a decision had been made to dismiss her application because of her failure to attend the hearing. The decision in question was said to be based on the provision of section 426A(1A)(b) of the Migration Act and was entitled a non-appearance decision.
The non-appearance decision, which was provided to the applicant via her email address, provided a recital of what had occurred, in an administrative sense, up to that point. It noted the invitation and that the applicant had not appeared in response to it and had not provided any explanation for so doing. The applicant has not formally put any of these conclusions into issue. The Tribunal said as follows:
“The applicant was invited under s.425 of the Migration Act 1958 (the Act) to appear before the Tribunal on 25 November 2016 at 9.30am but did not appear at the scheduled time and place. As no satisfactory reason for the non-appearance has been given, the Tribunal has decided to dismiss the application without further consideration of that application or the information before the Tribunal.”[4]
[4] Ibid at page 90
In the relevant letter, the applicant was also advised that she could apply, in writing, to have her application reinstated, if she did so no later than 9 December 2016. Accordingly, the dismissal was not in final terms, as the Tribunal indicated as follows:
“You may apply to us, in writing, for reinstatement of your application by 9 December 2016. In a reinstatement application you should set out why you failed to appear at the hearing and provide any other information you want the Tribunal to take into consideration when deciding whether your reinstatement application should be granted.”[5]
[5] Ibid at page 88
The applicant did not take advantage of the opportunity to apply to have her application reinstated or provide any subsequent information as to why she had failed to respond to the invitation to give evidence in support of her claim for protection. In particular, she did not advise the Tribunal as to why she had failed to attend at the relevant hearing.
On 12 December 2016, the relevant Tribunal member handed down what was entitled the decision record in this matter, which was to confirm the decision to dismiss the application. In support of its decision, the Tribunal determined as follows:
“On 25 November 2016 the Tribunal dismissed the application under s.426A(1A)(b) of the Act as the applicant did not appear before it to give evidence and present arguments at the time and date of the scheduled hearing.
The applicant was notified of the dismissal decision and given a copy of a written statement setting out the decision and the reasons for the decision, in accordance with s.426B(5). The applicant was advised that reinstatement of the application could be sought within 14 days of receiving the dismissal statement and that a failure to apply for reinstatement within the 14 day period would result in confirmation of the dismissal decision.
As the applicant did not apply for reinstatement of the application within the 14 days period, the Tribunal must confirm the decision to dismiss the application. In these circumstances, the decision under review is taken to be affirmed.”[6]
[6] Ibid at page 94
The grounds of appeal
The applicant has prepared her own application. She seeks a constitutional writ (certiorari) quashing the AAT decision. Thereafter she seeks a further constitutional writ (mandamus) directing the Tribunal to determine her application according to law.
She has provided three grounds in support of her application, which read as follows:
“1. AAT is wrong in law to dismiss my application.
2. AAT is wrong in law by giving no reasons to dismiss my application.
3. AAT is wrong in law and should give me a chance to give evidence.”[7]
[7] Ibid at page 4
The application is supported by an affidavit of the applicant, which simply annexes the relevant reasons for decision of 12 December 2016, which have been detailed above but provides no further evidence or submissions in support of the application.
The legislative framework
Division 4 of Part 4 of the Act provides the procedure to be followed by the Tribunal, in reviewing decisions arising under the Act. In particular, pursuant to section 425, the Tribunal is obliged to invite the relevant applicant to appear before it to give evidence and present arguments relating to the issues arising in relation to the decision under review.
In this case, there is no controversy that such an invitation was offered to the applicant and provided to her in writing, via her email address, well in advance of the scheduled hearing date. This was the invitation letter of 17 August 2016
Section 425A of the Act sets out what information invitation notices must contain and the manner in which they are to be brought to the attention of the invitee concerned. The relevant invitation must contain details of the day, time and place at which the applicant is scheduled to appear to give evidence. In this case, there is no controversy that this information was contained in the relevant invitation letter.
Section 425A(2) prescribes the manner in which the invitation is to be conveyed to the relevant applicant concerned. It makes references to section 441A and indicates that the notice must be provided by one of the methods contained in that section.
Section 441A provides an exhaustive list of methods by which the Tribunal is taken to have given a document prescribed by the Act. Pursuant to section 441A(5), it includes a Tribunal member or officer transmitting the document in question by fax; email; or other electronic means.
The invitation letter was forwarded to the applicant at the email address provided by her in her application. She did not subsequently update this address, which is consistent with the email address endorsed in her current application before the court.
Regulation 4.35D(3) of the Migration Regulations 1994 prescribes a period of fourteen days for the provision of an invitation to appear before the Tribunal prior to the date scheduled for the relevant hearing. In this case, the relevant invitation letter was issued on 17 August 2016 and the hearing date was 25 November 2016. On my calculations, the notice provided is well in excess of 90 days.
In addition, the relevant invitation notice must contain a statement, setting out the Tribunal’s discretion to dismiss an application, without any further consideration, pursuant to the provisions of section 426A, if an applicant does not appear when scheduled to do so.
Accordingly, in my view, there is no apparent irregularity in the manner in which the applicant was invited to appear before the Tribunal. In any event, the applicant herself does not assert any such irregularity. It therefore falls to determine whether there is any irregularity arising under section 426A of the Act and the other section which it references.
In the event an applicant fails to appear in response to an invitation to give evidence, the section authorises the Tribunal to either make a decision on the day in question or dismiss the application. Although both procedures will have the same consequence, the manner in which they are achieved is different, as the latter has a provisional quality, being subject to a possible right of reinstatement.
Section 426A provides as follows:
“Failure of applicant to appear before Tribunal
Scope
(1) This section applies if the applicant:
(a) is invited under section 425 to appear before the Tribunal; but
(b) does not appear before the Tribunal on the day on which, or at the time and place at which, the applicant is scheduled to appear.
Tribunal may make a decision on the review or dismiss proceedings
(1A) The Tribunal may:
(a) by written statement under section 430, make a decision on the review without taking any further action to allow or enable the applicant to appear before it; or
(b) by written statement under section 426B, dismiss the application without any further consideration of the application or information before the Tribunal.
Note 1: Under section 430A, the Tribunal must notify the applicant of a decision on the review.
Note 2: Under section 426B, the Tribunal must notify the applicant of a decision to dismiss the application.
Reinstatement of application or confirmation of dismissal
(1B) If the Tribunal dismisses the application, the applicant may, within 14 days after receiving notice of the decision under section 426B, apply to the Tribunal for reinstatement of the application.
Note: Section 441C sets out when a person (other than the Secretary) is taken to have received a document from the Tribunal for the purposes of this Part.
(1C) On application for reinstatement in accordance with subsection (1B), the Tribunal must:
(a) if it considers it appropriate to do so—reinstate the application, and give such directions as it considers appropriate in the circumstances, by written statement under section 426B; or
(b) confirm the decision to dismiss the application, by written statement under section 430.
Note 1: Under section 426B, the Tribunal must notify the applicant of a decision to reinstate the application.
Note 2: Under section 430A, the Tribunal must notify the applicant of a decision to confirm the dismissal of the application.
(1D) If the Tribunal reinstates the application:
(a) the application is taken never to have been dismissed; and
(b) the Tribunal must conduct (or continue to conduct) the review accordingly.
(1E) If the applicant fails to apply for reinstatement within the 14‑day period mentioned in subsection (1B), the Tribunal must confirm the decision to dismiss the application, by written statement under section 430.
Note: Under section 430A, the Tribunal must notify the applicant of a decision to confirm the dismissal of the application.
(1F) If the Tribunal confirms the decision to dismiss the application, the decision under review is taken to be affirmed.
(1G) To avoid doubt, the Tribunal cannot give a decision orally under subsection (1A), (1C) or (1E).
Other measures to deal with failure of applicant to appear
(2) This section does not prevent the Tribunal from rescheduling the applicant’s appearance before it, or from delaying its decision on the review in order to enable the applicant’s appearance before it as rescheduled.”
In summary, section 426A(1A) provides the Tribunal with a discretion as to how it is to proceed in the event an applicant fails to respond to an invitation letter, as is the case here. Pursuant to section 426A(1A)(a) & (b), it may do one of two things, namely:
·by written statement under section 430, make a decision on the review, without taking any further action to allow the applicant in question to appear before it – this results in a decision record;
·by written statement under section 426B dismissing the application without further consideration – this results in a non appearance decision, which is potentially subject to vitiation if a success application for reinstatement is made.
Section 430 provides details of what a decision on a review must contain. It is a written statement setting out the decision of the Tribunal in question and the reasons in support of that decision, including any necessary findings of fact on material issues. Ultimately, whether the application is dismissed pursuant to subsection (a) or (b) such a record must be produced, which will have the effect of completing the jurisdiction of the Tribunal.
The discretion to dismiss, provided by section 426B, is not without curbs or restraints. Pursuant to section 426A(1B), a person whose application is dismissed, as a consequence of a non appearance decision, may apply for reinstatement of his/her application within fourteen days of receiving notice of the decision.
Necessarily, as note 2 to section 426A(1A)(b) records, pursuant to section 426B, it is incumbent on the Tribunal to inform the applicant concerned of this right of reinstatement. Otherwise, for obvious reasons, such a right may be of little or no utility, so far as the applicant is concerned. The right of reinstatement only has currency for a period of fourteen days.
In theoretical terms, the subject of a non appearance decision, although his/her review has been dismissed, he/she is still able to approach the Tribunal in question in order to provide an explanation for not responding to the invitation offered and if the explanation is accepted to provide evidence to the relevant decision maker.
Section 426A(1C) details the obligations of the Tribunal, in the event that a person who had failed to appear in response to an invitation letter, applies for reinstatement. As the applicant in this case did not make such an application, this subsection has no application in this matter.
It is important to note however that it requires the Tribunal to provide written reasons, pursuant to section 430, if it declines to reinstate the application in question, which necessarily results in a completion of the jurisdiction conferred on the AAT.
The operative provision, in all the circumstances of this case, is section 426A(1E). After the provision of the non appearance decision, pursuant to section 426A(1A)(b) and in the absence of any application to reinstate the application, within the mandated period of fourteen days, the Tribunal is directed to dismiss the application in question but must provide written reasons in support of its application to do so pursuant to section 430.
On 12 December 2016, some seventeen days after the non appearance decision, the Tribunal provided further reasons, which confirmed the fact of the applicant’s non appearance in respect of the invitation letter and further confirmed that she had failed to make an application for reinstatement.
Section 426B provides the mechanics of what is required to occur, following a non appearance decision, made under section 426A(1A)(b), to complete the AAT’s jurisdiction, in the event that either no application to reinstate is made or there is a successful application to reinstate.
Pursuant to section 426B(2) the Tribunal is required to provide a written statement to the applicant setting out the decision made on the non appearance and the reasons in support of it. It is not as extensive in nature as a decision made under section 430.
However, pursuant to section 426B(4) the Tribunal has no power to vary or revoke a non appearance decision, once made other than, if it is subsequently nullified by a successful reinstatement application, the application in question is taken not to have been dismissed in the first place.
Accordingly, in the event that there is no successful application to reinstate, a non appearance decision cannot be revoked. Pursuant to section 426B(5), if a non appearance decision is made, it is necessary for the Tribunal to inform the non appearing applicant concerned of his entitlement to apply for reinstatement and the conditions which apply to this right.
Such an application must be made within 14 days of the non appearance decision being made. The section also provides that the notification of the reinstatement right must be provided by one of the mechanisms provided by section 441A, which as noted above, includes by electronic means.
Accordingly, the note provided to section 426A(1A) ties the provisions of section 426A and 426B together and, in effect, if the conditions of the latter are adhered to, transforms a non appearance decision into a decision record, if there is no successful application for reinstatement, fourteen days after the section 426B notice is provided. This decision is deemed to be final and cannot be thereafter revoked. Rather it is deemed to be affirmed pursuant to the provisions of section 426A(1F).
The evidence indicates that the applicant was informed of the non appearance decision by email on 25 November 2016. Pursuant to the provisions of section 441C, when a notice is provided by electronic means, it is taken to have been served at the end of the day on which it is transmitted.
In these circumstances, the evidence indicates as follows:
·the applicant was sent an invitation letter on 17 August 2016;
·the hearing to which she was invited was scheduled for 25 November 2016;
·the applicant did not attend the hearing;
·on 25 November 2016 her application was dismissed on the basis that she did not attend pursuant to section 426A(1A)(b);
·on 25 November 2016, the applicant was advised in writing of her right to apply to have her application reinstated;
·the applicant did not apply to have her application reinstated;
·more than fourteen days after 25 November 2016, on 12 December 2016 the applicant was advised that the Tribunal had confirmed the decision to dismiss her application;
·all relevant correspondence was forward to the applicant electronically and is therefore deemed to have been received by her on the day it was transmitted to her;
·as a consequence of the operation of section 426A(1F) the decision to dismiss the application was affirmed on 12 December 2016.
In summary, the legislative framework applicable required the Tribunal to affirm its decision to dismiss the application in the absence of any application for reinstatement. The Tribunal was not conferred with any jurisdiction to do otherwise.
Discussion
The applicant has provided generic grounds of appeal, in which she has asserted that the decision is wrong because she was provided with no evidence to support the decision in question and was not given an opportunity to present her case.
Given the applicant was properly invited to give evidence before the Tribunal but failed to appear, in my view, it cannot be said that there was no jurisdictional basis open to the Tribunal to make the decision which it did.
The applicable legislation, which I have detailed above, did confer upon the Tribunal jurisdiction to dismiss an application in the event an applicant failed to respond to an invitation to give evidence. Accordingly, I can see no merit in ground one of the appeal.
It is also the case that the Tribunal did give reasons, of the type envisaged by the applicable legislation, when it dismissed the application in question. It was not required to consider the substantive aspect of the applicant’s application for protection, in the event of a non appearance, if it decided to proceed under the alternative limb provided by section 426A(1A)(b).
Rather, it was required to provide a written statement, which it did together with necessary information regarding the applicant’s right to reinstatement, of which she did not take advantage. In these circumstances, I can discern no merit in ground two.
The applicant was further provided with an opportunity to give evidence to the Tribunal and was given ample notice of this opportunity. Accordingly, I do not accept that there is any merit in ground three of the appeal.
Although it is not the function of the court to make out any ground of appeal for the applicant before it or to search out any particular grounds which are not specifically articulated, the flavour of the applicant’s case is that it is in some way legally unreasonable that her application was dismissed without any formal evidence being taken from her.
In Minister for Immigration & Border Protection v Singh the Full Court identified two distinct areas in which a tribunal may fail to discharge the jurisdiction conferred upon it by acting in a manner which is legally unreasonable. Firstly, such a tribunal discharges its reasoning functions in a way which is unreasonable in the sense that it is illogical or otherwise lacking in intelligibility. Secondly, the outcome of the proceedings is coloured by caprice or arbitrariness. This second area is outcome focussed.[8]
[8] Minister for Immigration & Border Protection v Singh (2014) 231 FCR 437 at [44]
Accordingly, a failure to adjourn proceedings may be considered to be legally unreasonable, if the decision is considered to be capricious, particularly if limited or no reasons are given in support of it. In the circumstances, it may be open to a court conducting a judicial review to quash such a decision, given its supervisory role, if satisfied that it was not appropriate exercise of the power conferred on the tribunal in question or if it is unable to glean from the record itself why a particular decision was made.
Whether this is so or not will depend upon the evidence available to the court concerned and the overall circumstances of the case. Essentially, whether a procedural decision is legally unreasonable will be “invariably fact dependent…”[9]
[9] Ibid at [42]
In this particular case, the applicant in question had not attended to give evidence before the delegate or engage in any form of interview with the delegate. In addition, there is no suggestion that the electronic address provided by the applicant was deficient in any way or that she would not have received the SMS messages forwarded to her in anticipation of the hearing scheduled at the AAT.
In Kaur v Minister for Immigration & Border Protection[10] it was found to be legally unreasonable for a decision maker not to adjourn proceedings where an applicant had been readily able to be contacted and had otherwise responded to communications with the Department.
[10] Kaur v Minister for Immigration & Border Protection (2014) 236 FCR 393 at [138]
In these circumstances, it was found to be out of character for her not to have responded to a second invitation request, given her past behaviour and therefore unfair to dismiss her application, without some attempt being made to contact her further. Accordingly, it was found that the decision in question was vitiated by a denial of procedural fairness.
The applicant, in this case, has not asserted that there has been any specific breach of the provisions relating to non appearance arising under that Act or that the manner, in which the AAT sent correspondence to her, via electronic channels, was procedurally unfair to her in some way. As counsel for the Minister points out, the email address utilised by the AAT is the same one as the applicant has put on her application to this court.
MZALO v Minister for Immigration & Border Protection[11] was also a case concerning an applicant who had failed to appear in response to an invitation letter and whose application has been subsequently dismissed. Mortimer J distinguished the circumstances prevailing in this case from Kaur, which incidentally was a judgment of Her Honour. She said as follows:
“I do not consider there was anything that could be characterised as legally unreasonable in the way the Tribunal exercised its discretion under s 426A, given the circumstances of this particular review, and the appellant’s lack of contact with the Tribunal. There was no basis in the material before the Tribunal for it to consider that, if it adjourned the review, the appellant would attend an adjourned hearing and avail herself of the opportunity to present evidence and arguments in support of her claims…”
[11] MZALO v Minister for Immigration & Border Protection [2016] FCA 1339 at [28]
Similarly, in this matter, I do not think that there has been any procedural unfairness accorded to the applicant in all the circumstances prevailing in the case. She was given ample notice of the hearing before the AAT, after failing to attend at the Departmental interview. She was sent SMS reminders.
Most significantly, she was given an opportunity to apply to the Tribunal to have her application reinstated, which she did not take up. Accordingly, in my view, it was not legally unreasonable for the Tribunal to have confirmed the non-appearance decision, which in any event, it was obligated to do.
In these circumstances, I will dismiss the application for review and make an order for costs as sought by the Minister. The Minister seeks the sum of $4,000, which is just over half of the sum allowed by the applicable scale of costs for a defended hearing. In my view, this is a reasonable concession by the Minister.
For all these reasons, the orders of the court will be as set out at the commencement of these reasons for judgment.
I certify that the preceding seventy-one (71) paragraphs are a true copy of the reasons for judgment of Judge Brown
Date: 23 February 2018
Key Legal Topics
Areas of Law
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Administrative Law
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Immigration
Legal Concepts
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Judicial Review
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Natural Justice
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Procedural Fairness
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Jurisdiction
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