Kaur v Minister for Immigration, Citizenship and Multicultural Affairs
[2023] FedCFamC2G 959
•25 October 2023
FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA
(DIVISION 2)
Kaur v Minister for Immigration, Citizenship and Multicultural Affairs [2023] FedCFamC2G 959
File number(s): MLG 4330 of 2020 Judgment of: JUDGE SYMONS Date of judgment: 25 October 2023 Catchwords: MIGRATION – Student visa – decision of the Administrative Appeals Tribunal – whether the applicant could satisfy the genuine temporary entrant criterion under cl 500.212(a) of Schedule 2 to the Migration Regulations 1994 (Cth) – where Tribunal made finding applicant did not have substantial ties to home country including because she had not made visits to India during her period of study in Australia – whether this reasoning was unreasonable, illogical or irrational because it was based on assumptions for which there was no evidentiary basis – whether error material – application allowed with costs Legislation: Migration Act 1958 (Cth) ss 65, 359, 499
Migration Regulations 1994 (Cth) Schedule 2, cll 500.2, 500.212
Cases cited: Minister for Immigration and Border Protection v Stretton (2016) 237 FCR 1; [2016] FCAFC 11.
Plaintiff M1/2021 v Minister for Home Affairs (2022) 96 ALJR 497; [2022] HCA 17.
Division: Division 2 General Federal Law Number of paragraphs: 53 Date of last submission/s: 9 October 2023 Date of hearing: 9 October 2023 Place: Melbourne Counsel for the Applicant: Mr B Bromberg Solicitor for the Applicant: Carina Ford Immigration Lawyers Solicitor for the Respondents: Mills Oakley ORDERS
MLG 4430 of 2020 FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)
BETWEEN: GURPREET KAUR
ApplicantAND: MINISTER FOR IMMIGRATION, CITIZENSHIP AND MULTICULTURAL AFFAIRS
First Respondent
ADMINISTRATIVE APPEALS TRIBUNAL
Second Respondent
ORDER MADE BY:
JUDGE SYMONS
DATE OF ORDER:
25 OCTOBER 2023
THE COURT ORDERS THAT:
1.A writ of certiorari issue quashing the decision made by the second respondent on 24 November 2020.
2.A writ of mandamus issue requiring the second respondent to determine the application for review according to law.
3.The first respondent pay the applicant’s costs of the proceeding fixed in the sum of $8,371.30.
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 SYMONS:
INTRODUCTION
By an amended application filed on 11 September 2023, the applicant seeks judicial review of a decision of the second respondent (Tribunal) made on 24 November 2020. The Tribunal affirmed a decision of a delegate of the first respondent (Minister) to refuse to grant the applicant a Student (Temporary) (Class TU) (Subclass 500) visa (the visa) under s 65 of the Migration Act 1958 (Cth) (Act). The Minister opposes the application. The Tribunal entered a submitting appearance and has not participated in the proceeding.
BACKGROUND
The applicant is a citizen of India who arrived in Australia on 22 March 2018 on a tourist visa.
On 7 June 2018, the applicant applied for the visa (CB 1-22).
Pursuant to cl 500.2 of Schedule 2 to the Migration Regulations 1994 (Cth) (Regulations), it was a condition for the grant of the visa that the applicant satisfy a number of primary criteria, including what is referred to as the “genuine temporary entrant” (GTE) criterion which is contained in cl 500.212(a) and expressed as follows:
500.212
The applicant is a genuine applicant for entry and stay as a student because:
(a)the applicant intends genuinely to stay in Australia temporarily, having regard to:
(i)the applicant’s circumstances; and
(ii)the applicant’s immigration history; and
(iii)if the applicant is a minor—the intentions of a parent, legal guardian or spouse of the applicant; and
(iv)any other relevant matter; and
(b)…
(c)…
In an accompanying statement addressing the GTE criterion, the applicant explained that she was applying for the visa for the purpose of undertaking a Certificate IV in Commercial Cookery and a Diploma of Hospitality Management at the Imperial College of Australia and that she considered that these courses would enhance her cookery skills and be helpful in the pursuit of her dream of becoming a professional qualified chef and to open her own restaurant (CB 26 -28).
On 6 August 2018, a delegate of the Minister refused to grant the applicant the visa on the basis that she was not satisfied that the applicant genuinely intended to stay temporarily in Australia, and therefore cl 500.212 was not met (CB 37-41).
On 22 August 2018, the applicant applied to the Tribunal for review of the delegate’s decision (CB 42-43).
On 24 February 2020, the Tribunal invited the applicant, pursuant to s 359(2) of the Act, to provide further information about her ability to satisfy the requirement that she be enrolled in a registered course of study and the requirement that she be a genuine applicant for entry and stay as a student. The applicant was invited to provide this information through the completion of a Request for Student Visa Information form (CB 64-71).
On 6 March 2020, the applicant completed the online Request for Student Visa Information Form (CB 72-81). Under the heading, “Information about future plans”, the applicant wrote: “after completion of my studies I will go back to my home country to start my own independent business with the help of my husband and parents to start multicultural food restaurant”. When prompted to give details of the remuneration she would expect to receive in her home country using the qualifications gained from study in Australia, the applicant wrote: “I have a hope that after getting all studies from Australia. I have lot’s of opportunities to start my own business or I can easily get job with an good big hotel as head chef with handsome salary. My first choice is to start my own business” (CB 79). In the Form, the applicant provided her consent to the Tribunal deciding the review without a hearing (CB 73).
The applicant provided a separate written statement in which she sought to explain why she had chosen Australia for study and which the applicant referred to as her “GTE statement” (CB 82-83). Under the heading “Future plan”, the applicant wrote:
My husband two times came in Australia and went back. My purpose finish study and go back India and open my own business there. My family and my husband family everyone support us. My study fees already paid and my sister in law provide a free accommodation. So I have no more expenses have already finish more than 70% study. So I have a request to you please grant me a student visa for rest of my study and for my bright future. If you will not grant me a student visa my future will be ruined I hope you will take a right decision for my future.
The applicant provided a statement from her sister-in-law with whom she was living in Australia, documents evidencing her study and course enrolment in Australia, a statement from her parents and various documents relating to land and motor vehicles owned by family members in India (CB 84-114).
On 28 September 2020, the applicant sent an email to the Tribunal advising that she was due to complete her Advanced Diploma of Hospitality Management on 31 January 2021 and that she had enrolled in a further course (an Advanced Diploma of Leadership and Management) in respect of which she attached a Confirmation of Enrolment (CB 120-127).
THE DECISION OF THE TRIBUNAL
On 24 November 2020, the Tribunal affirmed the delegate’s decision to refuse the applicant the visa and published a written statement of decision and reasons (Reasons) (CB 137 -146).
The Tribunal identified the issue on review as being whether the applicant was a genuine applicant for entry and stay as a student (Reasons, [8]).
After reproducing cl 500.212 the Tribunal noted that in considering whether the applicant satisfied cl. 500.212(a), it was required to have regard to Direction No. 69 “Assessing the genuine temporary entrant criterion for Student visa and Student Guardian visa applications” made under s 499 of the Act (Reasons, [9]). The Tribunal noted that this Direction required it to have regard to a number of specified factors in relation to:
(a)the applicant’s circumstances in their home country, potential circumstances in Australia and the value of the course to the applicant’s future;
(b)the applicant’s immigration history;
(c)if the applicant was a minor— the intentions of a parent, legal guardian or spouse of the applicant; and
(d)any other relevant information provided by the applicant, or information otherwise available to the decision maker, including information that may be either beneficial or unfavourable to the applicant.
The Tribunal identified the material provided by the applicant in support of her application and reproduced in full her GTE statement provided to the delegate (Reasons, [15]-[16]).
The Tribunal accepted that the applicant had not come to Australia for the purpose of study but had travelled with her husband to stay with and visit her sister-in-law and her family. The Tribunal noted that the applicant’s husband had since returned to India and the applicant had remained in Australia living with her sister-in-law. The Tribunal accepted that the applicant had decided to obtain cooking qualifications after receiving compliments and encouragement from her family and sister-in-law when she cooked for a social event. The Tribunal noted that the applicant in the GTE statement to the delegate confirmed that she was seeking these qualifications so that she could return home and then obtain employment in a hotel or restaurant, with the intention of starting her own business (Reasons, [18]-[20]).
The Tribunal identified the applicant’s study, and proposed study, as:
(a)Certificate IV in Commercial Cookery from Imperial College of Australia (ICA) from August 2018 to January 2020 – completed;
(b)Diploma of Hospitality Management from ICA from February 2020 to July 2020;
(c)Advanced Diploma of Hospitality Management from Commercial College of Australia from August 2020 to January 2021;
(d)Enrolment in Advanced Diploma of Leadership and Management at ICA from 1 February 2021 to 30 January 2022.
The Tribunal found that the courses the applicant had undertaken, namely, the Certificate IV in Commercial Cookery and Diploma of Hospitality Management, would provide her with sufficient qualifications to work as a chef in India and commence her own business and would no doubt improve her employment prospects and remuneration (Reasons [23]). However, the Tribunal found that the subsequent enrolments in an Advanced Diploma of Hospitality Management and Advanced Diploma of Leadership and Management would have “extremely limited value to her goal to work as a chef”. The Tribunal observed that there was no contemplation of studying the Advanced Diplomas in the applicant’s GTE statement to the delegate and that it was inconsistent with the applicant’s stated intention of studying to become a chef. The Tribunal found that these (later) courses would only marginally improve the applicant’s employment prospects and level of remuneration in India and that the applicant could have undertaken a management course in India (Reasons, [24]- [25]).
The Tribunal noted that at the time of its decision, the applicant had been in Australia for 2 years and 8 months but that upon completion of the proposed Advanced Diploma of Leadership and Management the applicant’s total expected stay would be 3 years and 10 months, which the Tribunal found, including because it involved short vocational education training, was inconsistent with the stay being temporary (Reasons, [26]).
The Tribunal found that the applicant’s conduct in not having returned home to India during her stay in Australia was consistent with her wanting to stay in Australia permanently and not return home (Reasons, [38]). The issue of travel was also raised by the Tribunal in paragraphs [27] and [44] of the Reasons as follows:
27.The applicant has not returned home since arriving in Australia in March 2018. While the restrictions on travel due to the COVID-19 pandemic explain why she has not travelled home since March 2020, the fact she has not travelled home for the entire duration of her stay in Australia is more consistent with her wanting to remain in Australia permanently rather than to return home.
…
44.The applicant’s application for the student visa confirms that she has a mother, father, sister and brother back home in India, together with her husband and father-in-law which ordinarily would provide her with a substantial incentive to return home. However this must be balanced with the applicant’s circumstances as set out in the Response which confirms that save for her husband, she has not seen her family in India since March 2018 and now with her proposed course of studies, she does not intend seeing them for at least a further 15 months. Further the applicant has no job or substantial assets in India which would ordinarily create a substantial tie in India. By reason of the applicant’s intentions to continue her studies, it is expected that she will not see her parents and family in India in person for a total period of nearly four years. While the applicant claims she keeps in contact with family in India by WhatsApp and by telephone, having regard to her conduct and when balanced with her ties to Australia, the Tribunal is not satisfied that the applicant has substantial ties to her home country.
The Tribunal, on the other hand, found that the applicant had substantial ties to Australia. This finding reflected the fact that the applicant had lived in Australia with her sister-in-law and her family in Australia since March 2018 and had (through this arrangement) been in stable accommodation and with all expenses covered. The Tribunal also had regard to the level of income that the applicant might be projected to earn in Australia which, by reference to the minimum wage figures set by the Fair Work Commission, the Tribunal found would be substantially higher than the income she would be likely to earn in India as a chef (Reasons, [45], [36]).
The Tribunal was not satisfied that the applicant had made her application to gain a student visa to study temporarily. Instead, it found that the primary objective of the application was to maintain an ongoing residence in Australia and not remain in Australia temporarily (Reasons, [48]). The Tribunal was not satisfied that the applicant intended genuinely to stay in Australia temporarily and accordingly did not meet cl 500.212(a) of the Regulations (Reasons, [49]). The decision of the delegate was affirmed on this basis.
PROCEEDINGS IN THIS COURT
The applicant relies on an amended application and written submissions filed on 11 September 2023.
The Minister relies on written submission filed on 21 September 2023.
The amended application identifies the following two grounds of review:
1.The Tribunal’s finding that the Applicant does not have substantial ties to her home country because she has not returned home to India during her stay in Australia, was legally unreasonable, illogical or irrational, because it assumed that the Applicant had the financial means to readily visit her home country.
2.The Tribunal failed to give proper, genuine and realistic consideration to the value of the Applicant’s studies to her stated claim that she wishes to start her own business.
GROUND ONE
The submissions of the applicant
The applicant submits that the inference drawn by the Tribunal at Reasons [27] and [38] that the fact the applicant had not travelled home for the entire duration of her stay in Australia was more consistent with her wanting to remain in Australia rather than to return home was underpinned by an assumption that the applicant had the financial means to readily purchase return flights to India throughout the period March 2018 and March 2020, and chose not to.
This assumption was characterised by the applicant as illogical or irrational on the basis that it was not open to the Tribunal to assume that the applicant could afford to return home having regard to the following findings recorded by the Tribunal which, according to the applicant, coalesced in a profile of the applicant as a person who lacked independent financial means and provided an unsound basis upon which to draw conclusions about the applicant’s personal intentions:
(a)the applicant had incurred “a substantial outlay” in travelling to and undertaking studies in Australia (Reasons, [25]);
(b)all of the applicant’s “expenses are provided for her including her tuition fees” (Reasons, [32]);
(c)the applicant had not been employed or received income since arriving in Australia (Reasons, [33]); and
(d)the applicant was dependent upon persons other than herself, namely her family, for financial support (Reasons, [34]).
The applicant acknowledged that while there was some evidence before the Tribunal that the applicant’s mother and father owned real estate in India and motor vehicles, this evidence was not probative of whether the applicant (as distinct from the applicant in partnership with her parents and/or other family members) would be in a position to choose to expend funds to pay for a return trip to India. In the absence of a choice, a finding as to intention or the assigning by the applicant of a value to a decision to return home, was not available. The applicant made the further submission that the Court should be slow, in any event, to attribute this analysis (that involved the financial capacity of the applicant’s family members) to the Tribunal in circumstances where it did not appear in its reasons.
Submissions of the Minister
The Minister submits that it was open to the Tribunal, on the evidence before it, to proceed on the understanding that had she wished to visit her family in India, the applicant’s parents or her husband were willing and able to assist her by purchasing a ticket. The evidentiary basis was identified as:
(a)The statement contained in the applicant’s parents’ affidavit indicating “We will financial support to her [the applicant] or any type of help. If she need” (CB 98);
(b)The applicant’s claim that her husband “two times came in Australia and went back” (CB 82) from which it could be inferred that the applicant’s husband had the financial means to come to Australia two times and that the applicant herself would have the financial means if she wished to return to India to see her family.
The Minister further submits that there was no inconsistency in the Tribunal finding that the applicant’s willingness to remain in Australia where all of her expenses were provided for her and to incur substantial additional expenses after she had completed her Certificate IV in Commercial Cookery and her Diploma of Hospitality Management indicated that she wished to remain in Australia and its finding that her lack of interest in visiting her family in India indicated that she wished to remain in Australia.
Consideration
The parties are in broad agreement that ground one is to be assessed by reference to authorities that recognise that a decision or process of reasoning will be affected by unreasonableness, irrationality or illogicality where it is one which no rational or logical decision maker could arrive on the same evidence, including a decision that is lacking a rational foundation, or an evident or intelligible justification, or is plainly unjust, arbitrary, capricious or lacking common sense (see, for example, Minister for Immigration and Border Protection v Stretton (2016) 237 FCR 1, [11] per Allsop CJ).
I am persuaded that the findings recorded by the Tribunal regarding the applicant’s failure to travel back to India to visit family or more particularly, the inferences and then conclusions derived from this situation, are unsound because they lack both a rational foundation and, having regard to the Reasons, an evident or intelligible justification.
There is a quality of arbitrariness about the way the Tribunal approached the issue of the applicant’s travel. To start with, it is not apparent from the Reasons or from the decision of the delegate, that the applicant ever articulated an explanation for her failure to return to India to visit family during the period leading up to the date of the Tribunal decision or made any projections or representations about her planned travel in the future. The Tribunal had no direct evidence on the topic and was required, essentially, to speculate as to the applicant’s capacity and preparedness to undertake travel.
It is clear from the Reasons that the Tribunal proceeded, despite this, on the basis that there were no impediments of either kind and that the failure of the applicant to undertake travel to India was therefore instructive on the distinct but related topics of, the nature of the applicant’s intended stay in Australia (whether temporary or permanent) (Reasons, [28]) and [38]) and the strength of the applicant’s ties to her home country (Reasons, [44]).
The evidence on financial capacity was equivocal at best and, as the applicant submits, did not illuminate the question of whether the applicant herself was able to fund the cost of a return trip to India. The statement made by the applicant’s parents that they would financially support the applicant, or a statement to similar effect that appeared in the document provided by the applicant’s sister-in-law, did not supply a probative evidentiary basis for the assumptions made and inferences drawn by the Tribunal. Beyond the fact that the Tribunal did not identify these statements as supporting the findings made in the impugned paragraphs, the statements, read in context, suggest that any offer of financial support should be understood as directed at the applicant’s study, rather than at matters extraneous to this goal, including travel.
The arbitrary quality of the Tribunal’s reasons is reinforced in my view by the fact that on the Tribunal’s own reasoning, there was a satisfactory explanation for the applicant’s lack of travel that operated on the period from March 2020, and which reflected the difficulties with travel created by the COVID-19 pandemic (Reasons, [27]). Yet, the Tribunal’s conclusion on the issue of ties to India appears to take into account the entire period of the applicant’s past and proposed study in Australia, including a period of 15 months into the future about which the Tribunal had no evidence whatsoever about the applicant’s intentions (Reasons, [44]).
Finally, while I accept the submission of the Minister that there was nothing that strictly was inconsistent with the findings made by the Tribunal referred to at [31] above, the explanations offered by the applicant rather suggested that it was her intention to complete her studies in Australia without interruption so that she could return to India and to her family to open her own hospitality business.
The Minister did not put materiality in issue but in any case, the error in question here, having regard to the place of the travel findings as a component of the Tribunal’s reasoning on the strength of the applicant’s ties to India, comfortably achieves the threshold of being an error that if not made could have resulted in the Tribunal making a different decision.
GROUND TWO
The submissions of the applicant
The applicant submits that one of the key reasons for the Tribunal affirming the delegate’s decision was its finding made by reference to clause 12(b) of Ministerial Direction No. 69 (Direction) that the Advanced Diploma of Hospitality Management, which was being studied by the applicant at the time of the review, and the Advanced Diploma of Leadership and Management, which the applicant planned to study next, would “only marginally improve her employment prospects and level of remuneration in India” (Reasons, [24]). This finding in turn was based on an earlier finding that “[t]hose courses appear to have extremely limited value to [the applicant’s] goal to work as a chef”’ (Reasons, [23]).
In a similar vein, according to the applicant, the Tribunal recorded findings that the advanced diplomas “do not lead to a position as a chef and are all not connected and complementary to each other” and that the applicant’s change to her study pathway from commercial cooking to hospitality management to leadership and management could not be regarded as reasonable (Reasons, [28]-[29]).
The applicant submits that by making these findings, the Tribunal did not consider the value of the advanced diplomas to the applicant’s ambition to open her own business in India. It was said that this ambition had been clearly and articulately raised by the applicant in her GTE statement to the delegate (CB 26-29) and in her answers to the Request for Student Visa Information (CB 72-81) which demonstrated that at least by the time she completed this form, the applicant’s goals had crystallised as a plan to go back to India and to start her own business there (CB 82-83).
The applicant’s submissions contain an acknowledgement that the Tribunal Reasons do reveal a consciousness of the applicant’s ambition to open her own restaurant (refer Reasons at [23] and [25]). However, the principal complaint is that there was otherwise a conspicuous absence in the Tribunal’s Reasons, which were otherwise detailed and comprehensive, of any assessment by it of the value and relevance of the advanced diplomas to the applicant’s ambition to open her own restaurant business.
The applicant submits that by failing to intellectually engage in this assessment, the Tribunal failed to give proper, genuine, and realistic consideration to a clearly articulated claim which engaged a factor listed in the Direction and thereby fell into jurisdictional error.
The Minister’s submissions
The Minister submits that the applicant’s ground two should be understood and evaluated having regard to judicial statements that caution against the use of labels such as “genuine consideration” because they “have the danger of creating ‘a kind of general warrant, invoking language of indefinite and subjective application, in which the procedural and substantive merits of any [decision-maker’s] decision can be scrutinised” (referring to Plaintiff M1/2021 v Minister for Home Affairs (2022) 96 ALJR 497 (Plaintiff M1) at [26]).
The Minister disclaims any responsibility on the part of the Tribunal to undertake a “detailed and comprehensive” evaluation of the value of the two Advanced Diploma courses especially where the articulation of the applicant’s plans to start her own business suffered from a lack of detail.
The Minister submits that the Tribunal was plainly cognisant of the applicant’s claim that she wanted to set up a new business having regard to what was recorded at [25] of the Reasons.
Although the Minister appears to accept that the Tribunal did not undertake a detailed evaluation of the claim this is said to invite an inference that the Tribunal did not consider it was sufficiently material to warrant further mention.
Consideration
I am not persuaded that the Tribunal erred in the way described by the applicant in her ground two. While I accept that the Tribunal was required to consider and engage with the claim articulated by the applicant that her proposed courses of study would assist in her goal to open her own (hospitality) business, I am satisfied that the Tribunal’s Reasons indicate that it did undertake this evaluation.
In arriving at this conclusion, I acknowledge that the degree to which a decision-maker is required to engage with a claim will be informed, in part, by the “length, clarity and degree of relevance” of the claim or representation (Plaintiff M1 at [25]) and that there are no prescriptions around the manner in which – provided the minimum level of engagement occurs – this obligation is discharged.
In addition to the Tribunal expressly acknowledging the applicant’s claim at [20] and [25] of the Reasons, what is recorded at [23]-[24] assumes particular significance in understanding how the Tribunal approached its evaluation. These passages state:
23.The courses that she has undertaken including a Certificate IV in Commercial Cookery and Diploma of Hospitality Management would provide her with sufficient qualifications to work as a chef in India and commence her own business. Those courses would no doubt improve her employment prospects and remuneration. However the applicant is now studying an Advanced Diploma of Hospitality Management and wishes to study an Advanced Diploma of Leadership and Management. Those courses appear to have extremely limited value to her goal to work as a chef. The applicant had initially stated in the GTE Statement and her application confirmed that she had intended to study the Certificate IV in Commercial Cookery and Diploma of Hospitality Management to work as a chef. There was no contemplation of studying the Advanced Diploma courses.
24.While the Advanced Diploma of Hospitality Management is a hospitality course, it has limited value especially in light of the applicant having already obtained a Diploma qualification in that field. Further the Advanced Diploma of Leadership and Management which is predominantly a general management course, would have extremely minimal value in light of the hospitality management courses undertaken by the applicant, which are specific to the hospitality field and include a management component. Accordingly, the Tribunal considers that the courses that she is studying and intends to study will only marginally improve her employment prospects and level of remuneration in India.
Read fairly, what I understand the Tribunal to be communicating by these paragraphs is that the value of the Advanced Diploma of Hospitality Management and the Advanced Diploma of Leadership and Management to the applicant’s goal of working as a chef, and opening a (related) business, would be negligible in circumstances where (this being a finding made expressly at [23]) the two earlier completed courses would provide the applicant with sufficient qualifications to undertake both vocational goals. While the Tribunal might have expressed its conclusion regarding paragraph 12(b) of the Direction by reference only to the applicant’s goal to work as a chef, it was implicit in the Tribunal’s reasoning that the same analysis extended to the applicant’s sparsely articulated plans to open a business.
ORDERS
In circumstances where the applicant has enjoyed success on ground one of her amended application, I will order that the decision of the Tribunal be quashed and the matter returned to the Tribunal for reconsideration according to law. The Minister must pay the applicant’s costs in a fixed amount.
I certify that the preceding fifty-three (53) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Symons. Associate:
Dated: 25 October 2023
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