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

This matter concerned an application for Australian citizenship by Mr Muzafari, with the Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs as the respondent. The Administrative Appeals Tribunal (the Tribunal) was required to determine whether it was satisfied that the applicant was of good character, a prerequisite for the conferral of Australian citizenship under the *Australian Citizenship Act 2007* (Cth). The applicant had provided false information and a counterfeit licence to the Department and maintained this false information for over a decade.

The central legal issue before the Tribunal was whether the applicant had demonstrated he was of good character, given his history of providing false and misleading information to immigration authorities. This involved assessing the applicant's explanation for his conduct, his remorse, and the time elapsed since his last act of deception, in light of the statutory requirement for good character.

The Tribunal found that the applicant's prolonged course of objectionable conduct, which only ceased in late 2020, weighed significantly against his application. Despite other potentially positive aspects of his application, insufficient time had passed for him to be considered of good character. The Tribunal applied the principle that a refusal of citizenship does not prevent a future application once the applicant can demonstrate a sufficient period of good character, drawing on reasoning from *Fenn*. Consequently, the Tribunal affirmed the decision under review, meaning the application for citizenship was refused.