Kazim Hassan and Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs (Citizenship)

This matter concerned an application for Australian citizenship by conferral by Mr Kazim Hassan, who appealed a decision of the Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs. The central dispute revolved around whether the Administrative Appeals Tribunal (AAT) could be satisfied of Mr Hassan's identity under section 24(3) of the *Citizenship Act 2007* (Cth), given the limited documentary and biometric evidence provided, and the Tribunal's heavy reliance on Mr Hassan's life story. The Deputy President of the AAT heard the appeal.

The legal issue before the Tribunal was to determine whether it was satisfied of the applicant's identity for the purposes of granting citizenship by conferral, notwithstanding the scarcity of traditional identity documentation and biometric data. This required the Tribunal to consider how to assess identity when one of the established "pillars" of identity assessment – the applicant's life story – was given significant weight due to the limitations in the other pillars.

The Tribunal's reasoning emphasised an evidence-based approach to identity assessment, which involves establishing a person's identity from birth through an "identity timeline" and creating a complete "identity picture." While acknowledging the importance of documentary evidence and biometrics, the Tribunal noted that in cases where an applicant is stateless or undocumented, one pillar, such as the life story, may necessarily be given more weight. In such circumstances, it is crucial to explore further material, including credible open-source country information, to test and verify the applicant's claims and ensure consistency with the situation in their country of origin. The Tribunal considered Mr Hassan's life story, including details of his family composition, and found it to be consistent with the available information, thereby satisfying the requirements of section 24(3) of the *Citizenship Act 2007*.

The Tribunal affirmed the reviewable decision of 27 November 2019.