MORJARIA and Minister for Immigration, Citizenship and Multicultural Affairs (Citizenship)

MORJARIA and Minister for Immigration, Citizenship and Multicultural Affairs (Citizenship) [2022] AATA 2473 (4 August 2022)
Division:GENERAL DIVISION
File Number(s): 2021/1177
Re:Parag Bhagwanji Dayalal MORJARIA

APPLICANT

AndMinister for Immigration, Citizenship and Multicultural Affairs
RESPONDENT

File Number(s):2021/1179
Re:Deshan Parag MORJARIA

APPLICANT

AndMinister for Immigration, Citizenship and Multicultural Affairs
RESPONDENT

DECISION
Tribunal:The Hon. John Pascoe AC CVO, Deputy President
Date:4 August 2022
Place:Sydney

The correct or preferable decision in both matters is to affirm the decisions under review.
.............................[SGD]........................................
The Hon. John Pascoe AC CVO, Deputy President
CATCHWORDS
CITIZENSHIP – by conferral – delegate not satisfied of likelihood to reside or of close and continuing association – applicant not in Australia at time of delegate’s decision – dependent applicant – under the age of 18 – not a permanent resident at the time of the delegate’s decision – decisions under review affirmed.
LEGISLATION
Australian Citizenship Act 2007 (Cth) s 21, 24
CASES
Re Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634
SECONDARY MATERIALS
Australian Citizenship [Policy Statement]
Citizenship Procedural Instruction 11 – Assessing likelihood to reside or continue to reside in, or maintain a close and continuing association with Australia
REASONS FOR DECISION
The Hon. John Pascoe AC CVO, Deputy President
4 August 2022

This decision relates to applications made on 28 February 2021, by which the applicants sought review of decisions made by a delegate of the respondent made on 1 February 2021 to refuse to grant the applicants’ citizenship by conferral under s 24(2) of the Australian Citizenship Act 2007 (‘the Act’).
BACKGROUND
The Respondent’s Statement of Facts, Issues and Contentions contains a helpful summary of the background of this matter, which is replicated below.
The applicant is a 51 year old British Citizen. His son, Deshan is a 14-year old British Citizen. Both the applicant and Deshan first arrived in Australia on Tourist (subclass 676) visas in early November 2012.
Deshan and the applicant then departed in November 2012, staying approximately three weeks, and when they were offshore, they were both granted a Skilled – Nominated (subclass 190) visa on 10 October 2013. They then returned to Australia in November 2013 and predominantly resided in Australia until their departure in December 2017.
On 6 December 2017, the applicant applied for Australian citizenship by conferral. Deshan was included as a dependent child of the applicant for the purpose of the application. As noted, the applicant and Deshan then departed Australia some seven days later, on 13 December 2017. They have not returned since.
On 10 October 2018, the Skilled – Nominated (subclass 190) visas held by the applicant and Deshan ceased.
On 19 October 2020, the Department invited the applicant to provide information relevant to the assessments under s 21(2)(g) and s 24(5) of the Act
On 4 December 2020, the applicant, through his legal representative, provided submissions and evidence to the Department advancing reasons why he had not returned to Australia since December 2017.
On 11 November 2020, the applicant applied for a Resident return (subclass 155) visa (resident return visa). Deshan was not an applicant in the resident return visa application. On 8 February 2021, the applicant was granted the resident return visa.
It appears, on the visa records produced by the Respondent before the Tribunal, that the applicant’s return resident visa appears to have since ceased due the applicant not entering Australia by 8 February 2022.
On 1 February 2021, a delegate of the Minister (delegate) refused to approve the applicant’s application for citizenship. The delegate was not satisfied that the applicant satisfied s 21(2)(g) of the Act. The delegate also determined that they were prohibited from approving the application under s 24(5) of the Act in circumstances where the applicant was not present in Australia at the time of the decision.
On the same day, a delegate of the Minister refused to approve Deshan becoming an Australian citizen. The delegate found that as Deshan’s Subclass 190 visa ceased on 10 October 2018, he did not satisfy the permanent resident requirement under s 21(5)(b)(ii) of the Act.
Deshan has not been granted another visa since the expiry of his Skilled – Nominated (subclass 190) visa on 10 October 2018.
On 28 February 2021, the applicants applied to this Tribunal for review of those decision.
THE LAW AND POLICY
The Act
The decision-maker, and the Tribunal on review, is required to assess the applicant's application for citizenship against the 'general eligibility' criteria at subsection 21(2) of the Act.
Subsection 21(2) provides:
A person is eligible to become an Australian citizen if the Minister is satisfied
that the person:
(a)is aged 18 or over at the time the person made the
application; and
(b)is a permanent resident:
(i) at the time the person made the application; and
(ii) at the time of the Minister’s decision on the application; and
(c) satisfies the general residence requirement (see section 22) or the special residence requirement (see section 22A or 22B), or satisfies the defence service requirement (see section 23), at the time the person made the application; and
(d)understands the nature of an application under subsection (1); and
(e)possesses a basic knowledge of the English language; and
(f)has an adequate knowledge of Australia and of the responsibilities and privileges of Australian citizenship; and
(g)is likely to reside, or to continue to reside, in Australia or to maintain a close and continuing association with Australia if the application were to be approved; and
(h)is of good character at the time of the Minister’s decision on the application.
Section 21(5)(b) of the Act provides that a person is eligible to become an Australian citizen if the Minister is satisfied that the person was a permanent resident:
(i) at the time the person made the application; and
(ii) at the time of the Minister’s decision on the application.
Section 24(1A) of the Act provides that a person must not be approved to become an Australian citizen “unless the person is eligible to become an Australian citizen under subsection 21(2), (3), (4), (5), (6), (7) or (8)”.
Section 24 provides for certain circumstances in which the conferral of Australian citizenship is prohibited. Section 24(5) of the Act provides that the Minister must not approve the person becoming an Australian citizen at a time when the person is not present in Australia if, relevantly:
(i)the person is covered by s 21(2),
(ii)the person does not satisfy the special residence requirements in ss 22A or 22A, and
(iii)the Minister did not apply ss 22(9) or 22(11) in relation to the person.
The policy
The relevant policy to be considered in this matter is relevantly provided below. The Tribunal also takes into account the Australian Citizenship [Policy Statement], which provides general guidance on citizenship applications to decision-makers. The Tribunal accepts that it should apply the policy unless there are cogent reasons not to do so.[1]
[1] Re Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634
Relevantly, Citizenship Procedural Instruction (CPI) 11 – Assessing likelihood to reside or continue to reside in, or maintain a close and continuing association with Australia provides decision-makers with guidance on assessing the likelihood that a person will reside or continue to reside in Australia or maintain a close and continuing association with Australia.
CPI-11 provides that:
3.2. Only one arm of the requirement must be met
An applicant seeking to satisfy subsection 21(2), (3) or (4) of the Act must be likely to:
·     reside or continue to reside in Australia; or
·     maintain a close and continuing association with Australia if their application were to be approved.
This means the decision-maker must make a finding about the applicant’s future plans or intentions. The decision-maker may, if they consider it necessary, seek information relevant to this requirement by interview or a request for further information.
Likely to reside or continue to reside in Australia
The words comprising the phrase ‘likely to reside or continue to reside’ should be given their ordinary meaning in the context in which they appear. The Macquarie Dictionary Online defines:
·     ‘likely’ as probably or apparently going or destined (to do, be, etc.) – in the context of the requirements of the Act, this means it is probable rather than possible that the person will reside in Australia;
·     ‘reside’ as to dwell permanently or for a considerable time; have one's abode for a time – in the context of the requirements of the Act, this means the person’s home in which they ordinarily live is in Australia.
The person’s intention to reside in Australia should be investigated if the applicant has indicated they will:
·     be outside Australia during processing of their application; for example, they have asked to take the citizenship test or pledge overseas; or
·     reside outside Australia after obtaining citizenship; for example, they have indicated an intention to migrate elsewhere or to take up employment outside Australia
Likely to maintain a close and continuing association with Australia
The words comprising the phrase ‘likely to maintain a close and continuing association’ should be given their ordinary meaning in the context in which they appear. The Macquarie Dictionary Online defines:
·     ‘maintain’ as to keep in existence or continuance; preserve; retain;
·     ‘close’ as near, or near together, in space, time, or relation;
·     ‘continuing’ as to last or endure;
·     ‘association’ as the act of associating … connection or combination.
·     It is important to note that the requirement to maintain a close and continuing association refers to an association with Australia, not with Australians. This means that a close and continuing association with immediate/ extended family or other social relationships or networks in Australia may not be sufficient to meet this legal requirement, although the merits of every case must be carefully considered.
CPI 11 identifies factors that may be relevant when assessing whether an applicant is likely to reside or continue to reside in Australia, or maintain a close and continuing association with Australia should their application be approved, which include:
(a)their living arrangements and citizenship or migration status in their current country of residence (whether Australia or elsewhere);
(b)whether the person has any assets, commitments or ties to a country that may require or incline them to continue to reside in that country;
(c)the frequency and purpose of the person’s visits to Australia;
(d)the frequency and reasons for the person’s absences from Australia;
(e)the person’s participation in the Australian community;
(f)whether the applicant has a close family member (including a de facto partner) who is an Australian permanent resident or Australian citizen, and who intends on residing in Australia.
THE ISSUES
The issues for determination are:
(a)Whether Parag Bhagwanji Dayalal Morjaria (‘the applicant’) is likely to:
(i)reside or continue to reside in Australia if his application for citizenship were to be approved; or
(ii)maintain a close and continuing association with Australia if his citizenship application were to be approved: s 21(2)(g) of the Act; and whether the approval of his application is prohibited by virtue of s 24(5) of the Act.
(b)Whether Deshan Parag Morjaria (‘Deshan’) is a permanent resident for the purposes of s 21(5)(b) of the Act.
THE EVIDENCE
The evidence of Mr Parag Morjaria
I note that Mr Morjaria gave evidence in relation to both himself and his son Deshan, 14, who is also the subject of this decision.
The applicant started out by saying that he had taken a long time to come before the Tribunal because of his circumstances in the United Kingdom. The applicant said that he and his former wife had been involved in protracted family law proceedings which he said would finally end and that outstanding property issues would be dealt with.
He emphasised his commitment to return to Australia and to work with his friend Mr Mark Kalos to build a new business. He said he would definitely return to Australia and would be likely to continue to reside in Australia if his application was successful.
The applicant was born in Kenya in 1971 and went to the United Kingdom (‘UK’) to attend university around 1985. It appears that he did not complete university in the UK. He returned to Kenya to study and went back to the UK in the late 1990s. He said that his qualifications were ultimately gained in India where he completed a Bachelor of Engineering. He said he liked to work with his hands and that he worked on motorbikes, air conditioning, and similar things.
The applicant said that he had maintained a property in the UK since the 1990s. He had married and had two children; his daughter, ‘S’, born in 2002 and his son Deshan born 2008.The applicant said that he and his family had come to Australia as a family. Initially they had arrived on tourist visas but after returning to the UK they came back to Australia in 2014 on a skilled work visa which related to his wife’s qualifications.
They had moved to different places in Australia. Initially, the family had rented and then they purchased a home in Sorrento, which the applicant said had been purchased because of his wife’s desire for status. There had also been some problems with recognition of his qualifications. Unfortunately, although the applicant greatly enjoyed living in Australia, his wife wanted to return to the UK. She returned to the UK in 2015 but the children remained with the applicant in Australia.
About six months after the applicant’s wife left Australia, the applicant’s daughter wanted to go back to live with her mother and she also returned to the UK in late 2015. The applicant remained in Australia with his son Deshan in a property which the applicant owned.
The applicant said that he needed to return to the UK after a holiday in July 2017. Although he preferred Australia, he needed to be in the UK in order to sort out various problems. The applicant returned to Australia in July 2017 but left again in December 2017 after applying for citizenship for himself and Deshan. At the time he left, the applicant said he had a bank account in Australia with money in it and that he also left behind a number of possessions. The applicant stated that he had had to sell the Sorrento property before he left Australia.
In 2018, divorce proceedings were commenced in the UK and property proceedings were commenced in 2019. Final orders were made by the Court, which provided for the children to live with the applicant. When the wife finally left the matrimonial home in mid-2019, the children continue to live with the applicant until March 2020, when the applicant’s daughter S went to live with her mother.
When questioned, the applicant agreed that in 2019 - 2020 he failed to attend or had to have rescheduled about 10 citizenship tests. In February 2021, a decision was made to refuse the applicant’s citizenship application.
The applicant gave evidence that there were ongoing and very bitter financial proceedings between himself and his wife, in particular over the property in Millennium Way which continues to be the subject of ongoing proceedings, because his wife did not accept the original court decision and wanted more money. The property had in fact been sold shortly after listing, but the sale had not been able to be completed because of the wife’s ongoing proceedings. A number of other properties have been transferred to the wife.
The applicant gave evidence that he owns three flats in the city of Coventry in the UK and that essentially he sustained himself on the income from these properties. He had closed his business in the UK in 2012 when he came to Australia.
The applicant said that once everything has been finalised he wanted to return to Australia. At the current time, however, there was still a lot of uncertainty and therefore he did not have any particular date in mind. His intention was to acquire property in Australia within nine months of the UK family law proceedings having finally been settled. He noted that his prospective business partner, Mark, had already relocated to Perth and that they were developing plans for a business.
Deshan had initially been prevented from leaving the UK because of family law orders and was notable to leave with his father. Deshan is currently finishing year nine at school, going into year 10. The applicant gave evidence that he wants to go to university in the UK. The applicant’s daughter, S, is currently at university in the UK. The applicant confirmed that Deshan has not held a permanent visa in Australia since October 2018.
The applicant said that he had extended family in the UK but they were not particularly close. His father recently moved to the UK from Kenya. The applicant had two brothers in the UK and said that he had loans of approximately $10,000 from each of his brothers, and further outlined his plans to build a business in Australia with Mark.
He said that he would initially live in Mark’s property before renting himself and ultimately buying a property. The applicant said that he wanted to provide a stable life for Deshan in Australia. When questioned, however, the applicant agreed that he had not made any inquiries in relation to schooling for Deshan in Australia and said that it would depend upon where they lived. He would rely on Mark for income and accommodation initially.
The applicant emphasised that much of what had happened to him had been beyond his control and that he was committed to living in Australia. He was familiar with Australia, and had planned a future in Australia.
DISCUSSION
As previously outlined, there are two separate applications and issues to be addressed by the Tribunal. I will begin with Deshan’s application, and then turn to the applicant’s.
Applicant 2: Deshan Morjaria
The first question to be answered is whether Deshan was a permanent resident of Australia at the time of his application for citizenship on 6 December 2017, and at the time of the Minister’s decision on his application, namely that of 1 February 2021.
Deshan is currently aged 14. He must satisfy the eligibility criteria under s 21(5) of the Act. He was included as a dependent child in the applicant’s application for citizenship on 6 December 2017. At the time of the application, the applicant held a Skilled – nominated (190) visa (‘skilled nomination visa’). This visa expired in October 2018, and in November 2020, the applicant applied for a further visa.
As Deshan was and remains under the age of 18, he must meet the requirements of s 21(5) of the Act. Deshan did not meet the requirements of s 21(5)(b)(ii) at the time of the Minister’s delegate’s decision in February 2021 as his skilled nomination visa expired on 10 October 2018, at which time he was living with his family full time in the United Kingdom. Deshan did not hold any other visa on 10 October 2018, nor has he been granted any other Australian visa since its expiration or made an application for one.
Accordingly, it must be found that at the time of the Tribunal’s decision, Deshan is not a permanent resident of Australia and does not satisfy the requirements of s 21(5)(b)(ii) of the Act.
On the evidence given to the Tribunal, at the time of the Minister’s decision, Deshan was living with his family in Coventry, United Kingdom, and attending school in that city. He had not been the subject of any application for a visa which would allow him to return to Australia. In fact, the applicant gave evidence that Deshan had been doing well at school in the UK, despite the family difficulties, and wanted to go to university in that country, although I note the first applicant also gave evidence that if he were to return to Australia, Deshan would come with him.
Applicant 1: Parag Morjaria

The first applicant is required to satisfy one of two limbs of s 21(2)(g), namely that he is likely to reside or continue to reside in Australia; or that the applicant is likely to maintain a close and continuing association with Australia. The Applicant gave evidence to the Tribunal of how much he had enjoyed living in Australia. He had initially lived in rental accommodation in Australia but later purchased a house and also started a business which appears to have been quite successful. The Applicant said that he had never wanted to leave Australia, but that his wife was not happy in Australia and wanted to return to the UK. As a result, the family returned to the UK in December 2017 and established themselves in Coventry.
The Applicant gave evidence that he owned a number of properties in Coventry including the family home in Millennium Way and a number of investment properties.
Unfortunately, the Applicant and his wife became involved in very acrimonious family law proceedings which at the time of the hearing were yet to be finally resolved. The Applicant said that some property assets had been transferred to his wife and that the Family Court had made orders that the family home was to be sold. This was being resisted by his wife and on the Applicant’s evidence, it would ultimately be a matter for the Court to resolve.
From the evidence, it appeared that Deshan had lived with his father since returning to the UK but that his sister S had resided with their mother for much of the time the family has lived in the UK. S has now said to be attending university in the UK. There was no suggestion that she wished to return to Australia.
The applicant said that he had sold his business in the UK to fund family law proceedings and that essentially he had maintained himself and Deshan from the proceeds of renting three investment properties in Coventry. The applicant said he would either sell those properties if he were to return to Australia and use the proceeds to purchase a property in Australia once he was settled, or potentially place them in Deshan’s name instead.
The applicant also gave evidence that his intention was to start a new business in Australia with Mr. Mark Kalos and that they had been discussing plans for the new business. The Applicant said that he and Deshan could live with Mark for a period after he returned to Australia.
On the evidence, there is no doubt that the Applicant has a very strong desire to live in Australia. I accept his evidence that he did not want to leave and that he returned to the UK because of his wife. It does appear on the evidence that the family re-established themselves in the UK and purchased a number of properties, had business interests, and that the children attended school in the UK. In fact, the applicant gave evidence that despite all of the family problems, which had led to the involvement of child welfare authorities, Deshan continued to do well at school.
His evidence that Deshan wanted to attend university in the UK throws some doubt as to whether Deshan would remain in the UK. Further, there was no evidence produced as to anyone family court orders in relation time Deshan would spend with his mother. Further, there was no evidence whether his mother would consent to his returning to Australia with his father.
Accordingly, although it is possible, even likely, that Deshan would return to Australia with his father, it is not certain. Both the applicant’s children may therefore continue to reside in the UK, and this may be a factor that would affect the applicant’s return to Australia.
The Applicant’s business plans were all aspirational, and it did not appear that any concrete steps had been taken towards setting up a new business with Mr Kalos.
There was also no evidence that the applicant had taken any steps to look for or purchase a home in Australia. He had also not taken any steps in relation to identifying a suitable school for Deshan, which he explained was because he was not sure where he would ultimately settle in Australia, although he did give evidence that his business partner, Mr Kalos, had moved to Perth.
The applicant had not returned to Australia since leaving the country in December 2017. I accept that this may largely be explained by the ongoing family law proceedings, which are still not concluded.
In considering the entirety of the evidence, I am of the opinion that the applicant genuinely aspires to return to Australia, but I am not satisfied that the applicant is likely to reside in Australia. There are simply too many uncertainties. The Applicant’s family law proceedings have not concluded, at least one of his children, on the evidence, is unlikely to come to Australia, and given Deshan’s age, it is uncertain whether he would be able to return to Australia. The presence of his children in the UK may make it more difficult for the applicant to return to Australia. Further, his busines plans are embryonic rather than settled, and no concrete steps have been taken to set up a business in Australia.
The applicant still owns property in the UK, and has not taken any steps in relation to the purchase of property in Australia. In fact, on the basis of the evidence, he is unlikely to be able to do so until the sale of the matrimonial home has been completed and he has sold his investment properties in Coventry. Until that time, the amount of money he has to buy a home and invest in a business must be regarded as uncertain.
Turning to the second limb of s 21(2)(g), namely whether the applicant is likely to maintain a close and continuing association with Australia, it is again relevant that the applicant has, since leaving Australia, lived in the UK for a period longer than the time that he resided in Australia. He has not returned to Australia, so regular or indeed any physical presence is not a factor which can be relied upon to support his application.
I accept the applicant’s evidence that he loved the lifestyle in Australia, that he really enjoyed his time in this country, and that he would like to return at some stage. He made an application for citizenship seven days before departing from Australia which confirms that at least at that time he was intending to return as some time in the future. However, much has taken place since the date of that application that binds the applicant to the UK rather than to Australia.
There are, no doubt, many other people around the world who may have experienced Australia and would like to live in Australia. However, in order to satisfy the requirements of this part of s 21(2)(g), there needs to be evidence of some concrete investment or some emotional involvement or attachment with Australia. In this regard, nearly all of the applicant’s immediate family, including both his children and his two brothers, and much of his extended family, , live in the UK.
Any business interests the applicant has are in the UK. His evidence was that he maintained himself and Deshan from the proceeds of renting the three investment properties in Coventry, and that his main occupation was the maintenance of those properties. He has no property in Australia and although he has said he would like to buy a property in Perth, it would appear that he is currently unable to do so and there is no certainty as to when or how he would be able to fund a purchase of property in Australia.
The most significant ongoing relationship the applicant appears to have in Australia is with his proposed business partner Mr Mark Kalos. Mr Kalos did not give evidence at the hearing, although he submitted a letter to the Tribunal which said that the applicant was a close friend, that the applicant and his son would be able to live with Mr Kalos and his family were they to return to Australia, and that the applicant would be a valuable asset to his business because of his skills which were readily transferable.
There were some written statements of other friends of the applicant in Australia, however these were not discussed at hearing, nor were these people called to give evidence.
Given the applicant’s relatively short period of residence in Australia compared to the UK, there would need to be much stronger evidence of a close and ongoing association with Australia than is demonstrated by the evidence in this case.
Although I accept what the applicant has said about the fact that he loved his period in Australia, loves the Australian lifestyle, and the weather (as opposed to the weather in the UK) this is more indicative of an emotional attachment to Australia perhaps coloured by the very unfortunate circumstances the applicant has had to deal with in the UK, which include an ongoing and acrimonious divorce, the involvement of the welfare authorities in his family affairs, and the death of his mother.
On the evidence given to the Tribunal, the applicant does not have any family in Australia, nor does it appear that he has a large network of friends or business associates. On the evidence, there is Mr Kalos who is clearly a good friend a potential employer/business partner. There was no evidence that the applicant has any connection with community groups or other groups in Australia. In fact, on the evidence, it appears that apart from the ongoing contact with Mr Kalos, the applicant effectively severed his ties with Australia.
There is no evidence that the applicant has any property of any kind in Australia currently, and there was no evidence of any concrete plans for the purchase of property or investment of funds.
Accordingly, I cannot be satisfied that the applicant would maintain a close and continuing association with Australia.
I now turn to deal with s 24(5) – namely, that the delegate found that they were prohibited from granting the applicant’s application for citizenship on the grounds that the applicant was not present in Australia.
The applicant currently lives in the UK with his son. It is also of note that the applicant does not appear to currently hold an Australian visa. During the hearing, the applicant appeared from the UK via Microsoft Teams. There is nothing before the Tribunal to indicate that the applicant has entered Australia, or is present in Australia at the time of this decision.
I find that the prohibition in s 24(5) of the Act applies, and none of the exceptions to the prohibition regarding special residence requirements or the residence discretion apply.
Accordingly, I am unable to satisfied that the applicant meets the requirements under s 21(2)(g) of the Act. I also find that the prohibition to granting the applicant citizenship contained in s 24(5) applies.
CONCLUSION
It is difficult not to feel some sympathy for the applicant given the difficulties he has faced since he returned to the UK. The applicant would clearly like to have a better and happier life in Australia, but there is no evidence that Deshan meets the requirements of s 21(5(b)(ii) or the requirements of s 21(2)(g) or s 24(5) of the Act have been met in relation to the applicant himself. Accordingly, both applications must fail.
I note that it would be possible for the applicant to apply for a visa in the future which would allow him to move to Australia. It may be that the best course for him may be to settle of all of his affairs in the UK and return to Australia after that process has been completed.
DECISION
The correct or preferable decision in both matters is to affirm the decisions under review.

I certify that the preceding 79 (seventy -nine) paragraphs are a true copy of the reasons for the decision herein of The Hon. John Pascoe AC CVO, Deputy President

..............................[sgd]..........................................
Associate
Dated: 4 August 2022

Date(s) of hearing: 15 July 2022

Applicants: Self-represented

Solicitors for the Respondent: Mr A. Taverniti, Sparke Helmore Lawyers

[2022] AATA 2473

4 August 2022

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Statutory Construction

Jurisdiction

Date(s) of hearing:	15 July 2022
Applicants:	Self-represented
Solicitors for the Respondent:	Mr A. Taverniti, Sparke Helmore Lawyers