FEDERAL MAGISTRATES COURT OF AUSTRALIA
| FAROOQ v MINISTER FOR IMMIGRATION & ANOR | [2006] FMCA 865 |
| MIGRATION – MRT decision – jurisdiction erroneously declined under time limit – applicant unable to qualify on visa application – whether futile to order a writ of mandamus – whether visa application was invalid – whether Tribunal could allow visa application to be withdrawn – right of applicant to access Ministerial discretion – relief granted by Court. |
Administrative Decisions (Judicial Review) Act 1977 (Cth)
Migration Act 1958 (Cth), ss.46, 46A, 46B, 47, 48, 48A, 48B, 49, 347, 347(1)(b), 348, 349, 349(2)(c), 351, 351(1), 483A
Migration Regulations 1994 (Cth), regs.1.20C, 1.20D, 4.15(1), Sch.1 item 1223A(3)(d)(C)
Adams v Lambert [2006] FCA 623
Fernandez v Minister for Immigration & Multicultural & Indigenous Affairs [2005] FCA 1170
Jankovic v Minister for Immigration & Ethnic Affairs (1995) 56 FCR 474
Kumaraperu v Minister for Immigration & Multicultural Affairs (1998) 88 FCR 381
Nguyen v Minister for Immigration & Multicultural Affairs (1998) 88 FCR 206
SAAP v Minister for Immigration & Multicultural & Indigenous Affairs (2005) 215 ALR 162
Samad v District Court of NSW (2002) 209 CLR 140
X v Commonwealth (1999) 200 CLR 177
Xavier Fernandez & Ors v Minister for Immigration [2005] FMCA 960
| Applicant: | MUHAMMAD FAROOQ |
| First Respondent: | MINISTER FOR IMMIGRATION & MULTICULTURAL AFFAIRS |
| Second Respondent: | MIGRATION REVIEW TRIBUNAL |
| File Number: | SYG3348 of 2005 |
| Judgment of: | Smith FM |
| Hearing date: | 7 June 2006 |
| Delivered at: | Sydney |
| Delivered on: | 7 June 2006 |
REPRESENTATION
| Counsel for the Applicant: | Ms N Walker |
| Counsel for the First Respondent: | Ms D Watson |
| Solicitors for the Respondents: | Australian Government Solicitor |
ORDERS
A writ of certiorari issue directed to the second respondent, quashing the decision of the second respondent made on 4 March 2005 in MRT File No. N04/07476.
A writ of mandamus issue directed to the second respondent, requiring the second respondent to determine according to law the application for review of the decision of the delegate of the first respondent dated 19 October 2004.
The first respondent pay the applicant’s costs in the sum of $3,100.
| FEDERAL MAGISTRATES COURT OF AUSTRALIA AT SYDNEY |
SYG3348 of 2005
| MUHAMMAD FAROOQ |
Applicant
And
| MINISTER FOR IMMIGRATION & MULTICULTURAL AFFAIRS |
First Respondent
| MIGRATION REVIEW TRIBUNAL |
Second Respondent
REASONS FOR JUDGMENT
(revised from transcript)
I have before me an application filed on 16 November 2005 under s.483A of the Migration Act 1958 (Cth) (“the Migration Act”), which seeks orders by way of judicial review of the decision of the Migration Review Tribunal (“the Tribunal”) made on 4 March 2005. In that decision the Tribunal made a ruling that an application for review made by the applicant to it on 7 December 2004 had been brought outside the mandatory time limit under s.347(1)(b), and that it therefore lacked jurisdiction to conduct the review which was requested.
The applicant had sought review of a decision of a delegate taken on 19 October 2004, refusing an application made by the applicant on 17 August 2004…
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- Case
- [2006] FMCA 865
- Decision Date
CaseChat Overview and Summary
The legal issues before the court were whether the Tribunal had erroneously declined jurisdiction to conduct the review, and if so, whether the court should require the Tribunal to complete the exercise of its jurisdiction. The court also considered whether the Tribunal had powers which would allow Mr. Farooq to withdraw his original visa application, so as to be able to make another application with a different employer. The applicant contended that in the course of the review proceeding before the Tribunal, he would be able to obtain factual rulings of the Tribunal as to the course of administration taken within the Department when ruling upon the invalidity of the employer’s application, and then subsequently refusing the applicant’s visa on the ground of the absence of an approved employer.
The court found that the Tribunal had erroneously declined jurisdiction to conduct the review, and that it was appropriate for the court to require the Tribunal to complete the exercise of its jurisdiction. The court was inclined to accept the argument that the right of an applicant to withdraw his visa application under s.49 of the Migration Act ceases to be available once the Minister has taken a decision refusing to grant a visa. However, it was not necessary for the court to make clear rulings upon that issue. The court also found that it was appropriate for the court to quash the decision of the Tribunal and to require the Tribunal to determine according to law the application for review of the decision of the delegate.
The orders made by the court were as follows: 1. A writ of certiorari was issued, quashing the decision of the Tribunal made on 4 March 2005 in MRT File No. N04/07476. 2. A writ of mandamus was issued, requiring the Tribunal to determine according to law the application for review of the decision of the delegate dated 19 October 2004. 3. The first respondent was ordered to pay the applicant’s costs in the sum of $3,100.
Orders
Orders of the court
1.
A writ of certiorari issue directed to the second respondent, quashing the decision of the second respondent made on 4 March 2005 in MRT File No. N04/07476.
2.
A writ of mandamus issue directed to the second respondent, requiring the second respondent to determine according to law the application for review of the decision of the delegate of the first respondent dated 19 October 2004.
3.
The first respondent pay the applicant’s costs in the sum of $3,100.
Background
Background to the litigation
Full text does not contain this section.
Evidence
Evidence Before The Court
Full text does not contain this section.
Decision
Reasons for decision
Ratio Decidendi
Legal Principle Established
I have before me an application filed on 16 November 2005 under s.483A of the Migration Act 1958 (Cth) (“the Migration Act”), which seeks orders by way of judicial review of the decision of the Migration Review Tribunal (“the Tribunal”) made on 4 March 2005. In that decision the Tribunal made a ruling that an application for review made by the applicant to it on 7 December 2004 had been brought outside the mandatory time limit under s.347(1)(b), and that it therefore lacked jurisdiction to conduct the review which was requested. The applicant had sought review of a decision of a delegate taken on 19 October 2004, refusing an application made by the applicant on 17 August 2004 for a Long Stay Temporary Business Visa (Class UC) (subclass 457). By reason of the Tribunal’s decision that it did not have jurisdiction, it did not embark at all upon a consideration of various issues which the applicant wishes it to address. These concern the validity of his original visa application, his power to withdraw that application and make a fresh application nominating a different sponsoring employer, and his concerns about the good administration of the Department of Immigration in relation to the processing of his visa application. The subclass of visa which was applied for had a mandatory condition which required the applicant at the time of decision by the delegate, or by the Tribunal on review, to satisfy the decision‑maker that the employer proposed in his original visa application had received approval of the Minister under reg.1.20D of the Migration Regulations 1994 (Cth) (“the Regulations”), following a separate application for approval by that employer under reg.1.20C. The legislative provisions governing this criteria were addressed by me in Xavier Fernandez & Ors v Minister for Immigration [2005] FMCA 960 (“Fernandez”), which was upheld by Hill J in Fernandez v Minister for Immigration & Multicultural & Indigenous Affairs [2005] FCA 1170, and it is unnecessary for me to explore them again in this case. It was not contested by counsel for the applicant that the relevant criteria would not allow the applicant to “substitute” a different employer for the employer nominated in his original visa application. It was also conceded that the employer he identified in his visa application had subsequently gone into liquidation without ever obtaining approval, and that any future decision on his visa application would therefore never be able to reach satisfaction as to the criteria which is discussed in Fernandez. Prior to today’s hearing the first respondent considered evidence presented by the applicant that the Tribunal’s decision that the application for review was out of time was based on an incorrect factual finding as to when the applicant was notified of the delegate’s decision for the purposes of the deemed‑receipt provisions of the Migration Act. It is unnecessary for me to explore the evidence in this respect. It is now conceded that the Tribunal erroneously declined jurisdiction to conduct the review sought.