Kumar and Minister for Home Affairs (Citizenship)
[2019] AATA 3273
•5 September 2019
Kumar and Minister for Home Affairs (Citizenship) [2019] AATA 3273 (5 September 2019)
Division:GENERAL DIVISION
File Number(s): 2018/6724
Re:Anil Kumar
APPLICANT
AndMinister for Home Affairs
RESPONDENT
DECISION
Tribunal:Senior Member Damien O'Donovan
Date:5 September 2019
Place:Canberra
The decision under review is set aside and the matter is remitted to the Department with the direction that the discretion in s 22(4A) of the Australian Citizenship Act 2007 (‘the Act’) be exercised in favour of Mr Kumar to disregard the period of 29 March 2016 to 30 March 2016, when he was an unlawful non-citizen in Australia. Mr Kumar therefore satisfies the general residence requirement referred to in s 22(1)(b) of the Act.
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Senior Member Damien O'Donovan
CATCHWORDS
IMMIGRATION & CITIZENSHIP – refusal to grant citizenship by conferral – Ministerial discretion – administrative error - unlawful non-citizenship
Legislation
Australian Citizenship Act 2007 (Cth) ss 21, 22, 24
Migration Act 1958 (Cth) s 82Migration Regulations 1994 Schedule 2, Regulation 10.511
Cases
Chaudhary and Minister for Immigration and Citizenship [2010] AATA 1006, 53 AAR 561, 119 ALD 632
Drake v Minister for Immigration and Ethnic Affairs (1979) 46 FLR 409
Jabbour v Secretary of Home Affairs [2019] FCA 452
Minister for Immigration and Citizenship v Li [2013] HCA 18, 249 CLR 332, 87 ALJR 618, 297 ALR 225, 138 ALD 181
Minister for Immigration and Multicultural and Indigenous Affairs v Nystrom (2006) 228 CLR 566
Minister for Immigration and Border Protection v Farag [2015] FCA 646; 235 FCR 138
Project Blue Sky v ABA [1998] HCA 28SZDNK v Minister for Immigration [2004] FMCA 1080
Secondary Materials
Department of Immigration and Border Protection (Cth), Australian Citizenship Instructions, 1 July 2018, Chapter 5 - Citizenship by conferral
Department of Immigration and Border Protection (Cth), Citizenship Policy, 1 June 2016, Chapter 7 – Citizenship by conferralREASONS FOR DECISION
Senior Member Damien O'Donovan
5 September 2019
At 12:49 on 29 March 2016, as a result of a visa cancellation decision by a delegate within the Department of Immigration and Border Protection (the Department), the applicant, Mr Kumar, according to the respondent, entered a period of unlawful non-citizenship. He took immediate steps to remedy the situation and by the afternoon of the following day had in place a bridging visa which entitled him to remain lawfully in Australia.
The following year, on 19 April 2017, Mr Kumar applied for Australian citizenship. The application was rejected as a consequence of his status on 29 and 30 March 2016 because Mr Kumar could not satisfy the requirement that at no time in the four years prior to his application was he an unlawful non-citizen. The decision to reject his citizenship application is the decision under review.
The matter raises three issues for consideration. First, whether in the 4 years prior to his application for Australian citizenship, Mr Kumar was present in Australia as an unlawful non-citizen at any time. Second, if he was, whether the period of unlawful non-citizenship was because of an administrative error. Third, if any period of unlawful non-citizenship was the result of administrative error, whether as a matter of discretion that period should be disregarded for the purposes of determining whether Mr Kumar meets the general residence requirement for citizenship.
BACKGROUND
Mr Kumar is a citizen of India. He first arrived in Australia on 26 October 2008. On 3 October 2013 he was granted a Temporary Business Entry visa (“457 Visa”).
On 21 September 2015, Mr Kumar applied for a Regional Sponsored Migration Scheme (subclass 187) visa (“187 Visa”). On 21 September 2015, he also applied for a Bridging A (Class WA) (subclass 010) visa (“Class A Bridging Visa”).
The Class A Bridging Visa was granted that day but it never came into effect. Initially this was because Mr Kumar was the holder of a valid 457 Visa, but later, on 29 March 2016, the Class A Bridging Visa (according to the respondent) ceased to operate when Mr Kumar’s 457 Visa was cancelled.
Mr Kumar’s 457 Visa was cancelled on 29 March 2016 for non-compliance with a condition of that visa.
Mr Kumar was emailed the cancellation notice at 1.40pm that day. He became aware of it at 3.30pm and went straight to the Department’s office to deal with the issue. When he arrived at the Department’s office it was already closed for the day.
Overnight he filled out an application for a Class E Bridging Visa and the following day attended the Department’s office. A Class E Bridging Visa was granted at around 12pm on 30 March 2016.
On 15 April 2016, just over two weeks after his 457 Visa was cancelled and more than 6 months after he lodged his application, Mr Kumar’s application for a 187 Visa was processed and the visa granted.
On 19 April 2017, Mr Kumar applied for Australian Citizenship under the Australian Citizenship Act 2007 (‘the Act’).
On 27 September 2018, the delegate refused the application on the basis that Mr Kumar did not satisfy the general residence requirement in section 22(1)(b) of the Act. To satisfy the general residence requirement the person must not have been in Australia as an unlawful non-citizen at any time during the period of 4 years immediately before the day the person made the application.
The delegate found that Mr Kumar failed to meet that requirement on the basis of his status on 29 and 30 March 2016 described above.
Section 22(4A) of the Act allows the Minister (or their delegate) to treat a period as one in which the person was not present in Australia as an unlawful non-citizen if:
…the Minister considers the person was present in Australia during that period but, because of an administrative error, was an unlawful non-citizen during that period.
In making his decision, the delegate considered that he did not have any evidence to support the application of the discretion.
ISSUES
As noted above, the three questions which the Tribunal must consider are as follows:
(a)whether in the period from 29 March 2016 to 30 March 2016 Mr Kumar was an unlawful non-citizen;
(b)if he was, whether that status was because of an administrative error; and
(c)if it was, whether the discretion provided for in section 22(4A) of the Act should be exercised so that the period of unlawful non-citizenship is disregarded for the purposes of determining whether Mr Kumar meets the general residence requirement.
RELEVANT STATUTORY PROVISIONS
Section 21 of the Act relevantly provides as follows:
(1) A person may make an application to the Minister to become an Australian citizen.
(2) A person is eligible to become an Australian citizen if the Minister is satisfied that the person:
(a) …
(b) …
(c)satisfies the general residence requirement (see section 22)…at the time the person made the application;
Section 22 of the Act relevantly provides:
(1) Subject to this section, for the purposes of section 21 a person satisfies the general residence requirement if:
(a) the person was present in Australia for the period of 4 years immediately before the day the person made the application; and
(b) the person was not present in Australia as an unlawful non-citizen at any time during that 4 year period; and
(c) the person was present in Australia as a permanent resident for the period of 12 months immediately before the day the person made the application.
…
(4A) For the purposes of paragraph (1)(b), the Minister may treat a period as one in which the person was not present in Australia as an unlawful non-citizen if the Minister considers the person was present in Australia during that period but, because of an administrative error, was an unlawful non-citizen during that period;
SUBMISSIONS
Mr Kumar’s submissions proceed on the basis that there was a short period in which he was in Australia as an unlawful non-citizen. His submissions focus on the fact that prior to that period he had taken steps to ensure that he was in Australia lawfully, and sought to remedy his status as an unlawful non-citizen as quickly as was humanly possible when the situation arose.
Mr Kumar notes that he had applied for a Class A Bridging Visa that was granted on 21 September 2015 when he lodged his 187 Visa application and which he thought would come into effect when his 457 Visa was cancelled.[1] When he was advised of the cancellation of his visas he attended on the Department the next day and received a Class E Bridging Visa.
[1] Exhibit A1, at [4].
He notes that it was his intention to comply with all of the Department’s requirements and laws, including by disclosing to the Department the information which ultimately led to the cancellation of his 457 Visa.
Mr Kumar notes that if the delegate’s decision were upheld he will not meet the general residence requirement until 30 March 2020 and so will not be able to submit an application before then. Given current processing times he is unlikely to get a decision on any such application until 2022.
The respondent in his submissions contends that Mr Kumar was an unlawful non-citizen on 29 and 30 March 2016 in the time between the cancellation of the 457 Visa and the grant of the Class E Bridging Visa. Accordingly, Mr Kumar does not satisfy the general residence requirement unless a relevant discretion is applied.
The respondent contends that Mr Kumar’s period as an unlawful non-citizen was the result of a lawful administrative decision, prior to which the respondent had discharged all of its legal obligations. The respondent contends that there was no requirement in the Act for an applicant to be afforded time to regularise his status following a visa cancellation and the Department did not err in not affording Mr Kumar that opportunity. Further, Mr Kumar’s unlawful status arose in circumstances where he had been given prior notice of the intention to cancel and the cancellation was caused by his own failure to comply with the conditions of his visa – a matter that he was aware of. Further, he was on notice that, should his visa be cancelled, he would likely be an unlawful non-citizen. In those circumstances, nothing that was done could be said to constitute administrative error. Accordingly, the discretion to disregard the relevant period was not enlivened.
The approach taken by the respondent to the question of what could constitute ‘administrative error’ in its written submissions, which focussed on the lawfulness of what was done, was softened somewhat at the hearing. The respondent identified the approach taken by Deputy President Handley in the matter of Chaudhary and Minister for Immigration and Citizenship [2010] AATA 1006 (‘Chaudhary’) as an available approach. In that decision, DP Handley found that matters which did not affect the lawfulness of what the Department had done but which nonetheless fell short of “the appropriate course for a responsible departmental officer”[2] amounted to administrative error. The respondent, however, contended that no errors of a kind identified by Deputy President Handley occurred in Mr Kumar’s case.
[2] See Chaudhary at [36].
As Mr Kumar was self-represented and not legally trained, and in light of the Tribunal’s obligation to make the correct or preferable decision, a number of additional issues were explored with the respondent’s representative at the hearing at the Tribunal’s initiative.
Those issues were:
(a)whether Mr Kumar’s Class A Bridging Visa had, as a matter of law, ceased to be in effect upon cancellation of the 457 Visa;
(b)whether, having regard to either section 36 of the Acts Interpretation Act 1901 (Cth) or the legal maxim, de minimis non curat lex (the law does not concern itself with trifling matters), it could be said that Mr Kumar, who held a valid visa every single day of the four years prior to his citizenship application (but for part of two days did not), failed to meet the statutory requirement that he ‘not be present in Australia as an unlawful non-citizen at any time during that 4 year period’; and
(c)whether it was an administrative error to proceed with the decision to cancel the 457 Visa before dealing with his 187 Visa application, in circumstances where the inevitable result of dealing with the applications in that order was to induce a period of unlawful non-citizenship.
The respondent, in addition to addressing orally on these issues, was also given leave to file written submissions. It filed written submissions in relation to the issues raised in paragraphs (a) and (b) above.
In its engagement with the Tribunal, the respondent did not shy away from the harshness of the legal framework for which it contended.
It maintained its position that the Class A Bridging Visa ceased to have effect upon cancellation of the 457 Visa. It did not dispute that due to Migration Regulation 1994 requirements, Mr Kumar could not, in his particular circumstances, apply for a Class E Bridging Visa until he was an unlawful non-citizen[3]. Further, the respondent contended that even a period of a few minutes of lawful non-citizenship would be sufficient to disqualify a person from meeting the general residence requirement in the Act – the phrase ‘at any time’ was to be taken strictly and literally.[4]
[3] See the requirements in: Migration Regulations 1994, sch 2, reg 05-211.
[4] See Respondent’s Further Submissions filed on 18 July 2019 at [16] – [18].
The respondent accepted that within this legal paradigm, the inevitable consequence of proceeding with the 457 Visa cancellation (without first considering Mr Kumar’s 187 Visa application which had been submitted more than 6 months before), was that Mr Kumar would, as a practical matter, be unable to avoid a period of unlawful non-citizenship that disqualified him from meeting the general residence requirements in the Act and potentially exposed him to the other adverse consequences of that status. This was so despite Mr Kumar’s diligent attempts to remain legally compliant by submitting an application for a 187 Visa, applying for and receiving a Class A Bridging Visa at the time of his 187 Visa application, and immediately taking steps to acquire a Class E Bridging Visa upon being notified of the cancellation of his 457 Visa.
DECISION
Was Mr Kumar an unlawful non-citizen at any time?
For reasons explained below, I am satisfied that the decision by the delegate to proceed to make a decision to cancel Mr Kumar’s 457 Visa at the time, and in the circumstances in which he did, involved an administrative error. I am also satisfied that the available discretion should be exercised in Mr Kumar’s favour. In those circumstances, I have decided that it is not appropriate for me to determine the matter by reference to the question of whether Mr Kumar was ever in fact an unlawful non-citizen. Both parties proceeded on the basis that he was an unlawful non-citizen for a brief period between 29 March 2016 and 30 March 2016.[5] I do however have doubts that that was the case and against the possibility that it may become significant further down the track I have decided to set out the reasons for my reservations.
[5]I note that the respondent’s approach to the operation of the regulation is longstanding see: SZDNK v Minister for Immigration [2004] FMCA 1080 at [3].
In my assessment, a straight forward reading of the Migration Regulations produces the result that immediately following the cancellation of his 457 Visa, Mr Kumar held a valid Class A Bridging Visa.
The respondent accepts that Mr Kumar’s Class A Bridging Visa did not come into effect when it was granted on 21 September 2015.[6] Consequently, it could only come into effect when the 457 Visa ceased[7] (a term which includes cancellation)[8]. Notwithstanding that Mr Kumar never had his Class A Bridging Visa in effect while his 457 Visa was in effect, the respondent contends that the Class A Bridging Visa ceased to operate when his 457 Visa was cancelled by virtue of the operation of Migration Regulation 10.511(1)(b)(vi).
[6] Exhibit A7, Bridging Visa Grant Notice at pages 1 – 3.
[7] See Migration Regulation 1994, sch 2, reg 10.511(1)(a)(ii).
[8] The Act s 82(1).
To properly consider that proposition it is useful to set out the relevant parts of the Regulation.
010.5 When visa is in effect
010.511
(1) In the case of a visa granted to a non-citizen who has applied for a substantive visa – bridging visa:
(a)coming into effect:
(i) on grant; or
(ii) when the substantive visa (if any) held by the holder ceases; and
(b)permitting the holder to remain in Australia until:
(i)if the Minister’s decision in respect of the substantive visa application is to grant a visa – the grant of the visa; or…
…
(vi)if the substantive visa (if any) held by the holder is cancelled – that cancellation.
Two alternative approaches to the operation of the regulation appear open. The first is that the regulation contemplates a coming into effect and a ceasing to have effect which occurs sequentially by reference to circumstances existing at the relevant time.
Applying that sequencing to Mr Kumar’s case results in the following:
(a)He was granted a Class A Bridging Visa which did not come into effect on grant;
(b)His 457 Visa was subsequently cancelled (and therefore ceased[9]);
(c)By reason of that cancellation, his Class A Bridging Visa then commenced which permitted him to remain in Australia until the grant of his 187 Visa application. Sub paragraph (vi) had no application because at the point in time when his Class A Bridging Visa commenced he held no substantive visa because his 457 Visa was cancelled prior to and as a pre-condition for his Class A Bridging Visa coming into effect.
[9] The Act s 82(1).
Alternatively (which is the view favoured by the respondent) paragraphs (a)(ii) and (b)(vi) of regulation 10.511 do not operate sequentially, but effectively operate simultaneously if an applicant holds a substantive visa. Consequently, the applicant’s Class A Bridging Visa commences when the 457 Visa is cancelled and then the Class A Bridging Visa is immediately cancelled before it can do any work.
Choosing between the alternatives is not a straight forward interpretive exercise.
The respondent invites the Tribunal to read the words of sub-paragraph (b)(vi) in the second way. This interpretation, the respondent submits is preferable because, if it were otherwise, the sub-paragraph would have no work to do and accordingly it would violate the principle of statutory interpretation which requires that “no clause, sentence, or word shall prove superfluous, void or insignificant, if by any other construction they may all be made useful and pertinent.”[10]
[10] Respondent’s Further Submissions, at [10] citing Project Blue Sky v ABA [1998] HCA 28 at [71].
To make good this proposition the respondent provides one example of a factual circumstance where the provision would not have work to do. That is hardly sufficient to make good the general proposition for which the respondent contends. Further, it is most unlikely that the contention is correct. It appears to proceed on the assumption that a Class A Bridging Visa could not come into effect on grant and then be cancelled by sub-paragraph (b)(vi) when the substantive visa is cancelled. I doubt that assumption is correct. While it is true that Mr Kumar’s Class A Bridging Visa did not come into effect on grant[11] there does not appear to be a legal reason why it could not have. The High Court has made it clear that it is possible to hold two visas at the same time (see Minister for Immigration and Indigenous Affairs v Nystrom (2006 228 CLR 566) and there is nothing in section 82 of the Migration Act which prevents a bridging visa coming into effect when a substantive visa is in effect (indeed section 82(2) seems to specifically leave open such a possibility).[12] Consequently it appears that it was open to the Minister to bring Mr Kumar’s Class A Bridging Visa into effect while his substantive visa was in effect to ensure it was cancelled by the operation of sub-paragraph (b)(vi) if the substantive visa was cancelled.[13]
[11] See Migration Regulations 1994 (Cth) sch 2, reg 10.511; Exhibit A7, at 1.
[12] And section 82(3) of the Act only operates to cancel a bridging visa that is in effect, when a substantive visa comes into effect.
[13] Section 68 of the Act provides for this to occur.
Accordingly, there is a scenario in which the provision will have work to do.
The respondent does not point to any other principle of statutory interpretation which would favour its interpretation over the more straight forward sequential reading of the provision. If it were necessary for me to decide I would favour the conclusion that sub-paragraph (b)(vi) is not engaged if the bridging visa commences as a consequence of the cancellation of a substantive visa. It is however a difficult question of statutory interpretation and I am conscious that I would be departing from a long standing practice of the respondent.[14] As it is not necessary to resolve the question to dispose of the matter I have elected not to do so. The remainder of this decision proceeds on the basis that Mr Kumar was, for a period on 29 and 30 March 2016 an unlawful non-citizen.
[14] See SZDNK v Minister for Immigration [2004] FMCA 1080 at [3].
Was Mr Kumar an unlawful non-citizen in the relevant period because of an administrative error?
Unless it can be said that Mr Kumar’s period of unlawful non-citizenship on 29 and 30 March 2016 was because of an administrative error, there is no basis for disregarding the period of unlawfulness for the purposes of assessing the general residence requirement under s 22(1)(b) of the Act
It is therefore necessary to consider:
(a)what the threshold for an administrative error is,
(b)whether something which constituted an administrative error occurred, and,
(c)if it did, whether it caused a period of unlawful non-citizenship.
In its previous decision in Chaudhary the Tribunal considered that giving the words ‘administrative error’ their ordinary meaning in the context in which they appeared, referred to mistakes or errors made by the administrative or executive arm of government.[15] I am satisfied that approach is correct.[16]
[15] See Chaudhary at [32].
[16] The approach taken in the decision is referred to with apparent approval by Justice Robertson in Minister for Immigration and Border Protection v Farag [2015] FCA 646.
The respondent did not dispute the correctness of the Chaudhary decision, but submitted that mistakes of the kind which were present in Chaudhary were absent in Mr Kumar’s case. Implicit in this approach is the concession that it is not necessary for me to identify an error of such seriousness that it would support a successful application for judicial review. A mistake or error made by the administrative or executive arm of government as judged by reference to good administrative practice would be sufficient. In Chaudhary the standard applied for determining when a course of conduct constitutes a mistake or error was whether the conduct concerned would be regarded as the ‘appropriate course for a responsible departmental officer’.[17] In that case, because the Departmental officer’s conduct did not comply with a practice which was recommended as ‘more appropriate’ in the Procedures Advice Manual, the Tribunal found that the officer’s conduct constituted an administrative error.
[17] Chaudhary at [36].
In considering the question of what constitutes an administrative error I have had regard to the relevant parts of the Department’s Citizenship Instructions (‘Instructions’)[18] and the Department’s Citizenship Policy (‘Policy’).[19] The Policy notes that the concept of ‘administrative error’ embraces a range of administrative actions.[20] In broad terms it will extend to administrative mistakes and circumstances in which incorrect information is provided.’ It then lists a number of examples of administrative errors none of which are of assistance to Mr Kumar.
[18] Tribunal Documents (T-Documents) T7.
[19] T6.
[20] T6, folio 27.
The Policy then goes on to state that “[a] delay in processing an application does not constitute an administrative error in itself”[21]. I agree with that proposition.
[21] Ibid.
For completeness I note that nothing said in the Instructions or the Policy can alter the statutory test.[22]
[22] Drake v Minister for Immigration and Ethnic Affairs (1979) 46 FLR 409 at 419.
The question then is, has the delegate, or the Department, made an administrative error in the handling of Mr Kumar’s case which caused his period of unlawful non-citizenship.
In my assessment the Department has made such an error. The administrative error was to proceed to make a decision on Mr Kumar’s 457 Visa in circumstances where:
(a)Mr Kumar had submitted, more than 6 months prior, a valid application for an alternative substantive visa and Mr Kumar had been granted a Class A Bridging Visa to facilitate his presence in Australia pending consideration of that application;
(b)a decision on the 457 Visa would, on the Department’s understanding of the law, inevitably bring about a period of unlawful non-citizenship for Mr Kumar[23] and defeat the purpose of issuing the Class A Bridging Visa – ie to facilitate the consideration of his 187 Visa application;
(c)the Department understood, at least in general terms, that such a change in status could be seriously adverse to Mr Kumar’s interests; [24]
(d)Mr Kumar had made significant efforts to ensure that he did not fall into unlawful non-citizenship; and
(e)There was no identifiable public benefit in proceeding to revoke his 457 Visa in circumstances where its only effect was to create administrative difficulty for Mr Kumar but was otherwise unlikely to affect his continued presence in Australia or otherwise impact on his entitlement to the 187 Visa for which he had applied.[25]
[23] Exhibit A4, at 4.
[24] Ibid.
[25] Ibid.
The decision to proceed with the adverse 457 Visa decision, in the face of the pending 187 Visa application, with all its serious consequences for Mr Kumar, displays a kind of arbitrariness not very distant in substance from the facts considered by the High Court in Minister for Immigration and Citizenship v Li [2013] HCA 18 (‘Li’).[26] In Li, the decision to proceed to make a decision in unfavourable circumstances which were likely to change in the near future was regarded as unreasonable.[27]
[26] See in particular [30] and [31].
[27] It must be acknowledged that the Li decision involved the exercise of a statutory power whereas the present matter involves an unconfined administrative discretion about how the work of the Department should be organised. Accordingly, the closeness of the analogy should not be overstated. However the approach taken by the Court in Li is useful in giving content to the standard for good administrative practice – particularly so in circumstances where the scope for judicial review of pure executive power on reasonableness grounds appears to be expanding – see for example Jabbour v Secretary of Home Affairs [2019] FCA 452 at [91].
In my assessment to proceed to make a decision in relation to the 457 Visa in advance of a decision concerning the 187 Visa was not an appropriate course for a responsible departmental officer to take[28] and in that sense it was a mistake. Accordingly, the decision to proceed in those circumstances amounted to an administrative error.
[28] to use the words of DP Handley in Chaudhary.
As it was the decision to proceed with the 457 Visa cancellation decision that led directly to Mr Kumar becoming an unlawful non-citizen for the relevant period,[29] I am satisfied that it was because of the administrative error which I have identified, that Mr Kumar was an unlawful non-citizen during that period.
[29] This is assuming that my legal analysis of the operation of Migration Regulation 10.511 is not correct.
Consequently, the discretion to, in effect, ignore the period in which Mr Kumar was an unlawful non-citizen is enlivened.
In the present case I am satisfied that the discretion should be exercised favourably to Mr Kumar. I am of that view because:
(a)the period of unlawful non-citizenship was extremely brief;
(b)when Mr Kumar became aware that he was an unlawful non-citizen he took immediate steps to remedy the situation; and
(c)prior to becoming an unlawful non-citizen, Mr Kumar had gone to considerable efforts to ensure that he did not become an unlawful non-citizen.
For these reasons I make the following decision:
The decision under review is set aside and the matter is remitted to the Department with the direction that the discretion in s 22(4A) of the Act be exercised in favour of Mr Kumar to disregard the period of 29 March 2016 to 30 March 2016 when he was an unlawful non-citizen in Australia. Mr Kumar therefore satisfies the general residence requirement referred to in s 22(1)(b) of the Act.
I certify that the preceding 58 (fifty eight) paragraphs are a true copy of the reasons for the decision herein of Senior Member Damien O’Donovan.
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Associate
Dated: 5 September 2019
Date of hearing: 2 July 2019 Applicant:
Solicitors for Respondent:
Mr Anil Kumar, in person
Mr Andrew Keevers, Sparke Helmore
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