Opoku v Minister for Immigration, Citizenship and Multicultural Affairs

Case •

[2022] FedCFamC2G 945

Federal Circuit and Family Court of Australia

(DIVISION 2)

Opoku v Minister for Immigration, Citizenship and Multicultural Affairs [2022] FedcFamC2G 945  

File number(s): MLG 2304 of 2018
Judgment of: JUDGE EGAN
Date of judgment: 16 November 2022
Catchwords:  MIGRATION – Whether Tribunal fell into jurisdictional error by failing to reconvene for the purpose of canvassing live issues – whether failure of the Secretary to provide the Tribunal with relevant documentation constituted jurisdictional error – procedural fairness requirements under s. 360 of the Act – error established – decision quashed.
Legislation:

Section 360 of the Migration Act 1954 (Cth)

Regulation 124(b) of Schedule 1 to the Migration Regulations 1994 (Cth)

IMMI 12/116  
Cases cited:

Dang v Minister for Immigration & Anor [2016] FCCA 1426

Nathanson v Minister for Home Affairs [2022] HCA 26  

Pham v Minister for Immigration and Border Protection [2018] FCA 1946

Szbel v Minister for Immigration and Multicultural and Indigenous Affairs (2005) 228 CLR 152

Thaworn v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 2133
Division: Division 2 General Federal Law
Number of paragraphs: 29
Date of last submission/s: 14 November 2022
Date of hearing: 14 November 2022
Place: Brisbane
Counsel for the Applicant: Mr A White
Solicitor for the Applicant: Goz Chambers Lawyers
Counsel for the First Respondent: Ms K McInnes
Solicitor for the First Respondent: Australian Government Solicitors
Second Respondent: Submitting appearance save as to costs

ORDERS

MLG 2304 of 2018

FEDERAL CIRCUIT AND FAMILY COURT OF AUSTRALIA (DIVISION 2)
BETWEEN:

MR JOSEPH OPOKU

Applicant
AND:

MINISTER FOR HOME AFFAIRS

First Respondent

ADMINISTRATIVE APPEALS TRIBUNAL

Second Respondent

order made by:

JUDGE EGAN

DATE OF ORDER:

16 november 2022

THE COURT ORDERS THAT:

1.The name of the First Respondent be amended to read “Minister for Immigration, Citizenship and Multicultural Affairs”

2.The Further Amended Application for Review filed on 12 October 2022 be granted.

3.The decision of the Administrative Appeals Tribunal made on 15 April 2016 be quashed.

4.A writ of mandamus issue directed to the Administrative Appeals Tribunal requiring it to determine according to law the Applicant’s application for review of the Second Respondent’s decision, and that the matter be remitted to the Administrative Appeals Tribunal for rehearing.

5.For the purpose of the Administrative Appeals Tribunal again determining the Applicant’s application, it be constituted by a different member than the member who handed down the decision on 15 April 2016.

6.The First Respondent pay the Applicant’s costs of and incidental to the application for review fixed in the amount of $7,853.00.

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 Egan

Introduction

  1. The Applicant is a citizen of Ghana who arrived in Australia on 26 October 2008.

  2. On 24 December 2012, the applicant applied for a Temporary (Subclass 820) Partner Visa and a Permanent Partner (Subclass 801) Visa. At that time, the applicant was said to be in a spousal relationship with an Australian citizen who was his sponsor.

  3. On 10 May 2013, the applicant was granted a Temporary Partner Visa.

  4. On 21 March 2014, at a time prior to a decision being made in relation to the application for a Permanent Partner Visa, the applicant’s partner/sponsor withdrew her sponsorship for the visa on the basis that the relationship had ceased. On 25 July 2014, the applicant was invited to comment on the withdrawal of the visa sponsorship.

  5. On 16 September 2014, the applicant provided a written submission which included allegations that the relationship had ceased due to family violence perpetrated upon him by his former partner/sponsor. 

  6. In purported compliance with the first respondent’s evidentiary requirements relating to the making of family violence claims, the applicant provided additional documentation, which included a statutory declaration dated 29 September 2016 provided by one Halakhe Ganyu, who relevantly was a social worker.

  7. On 15 April 2016, a delegate of the Minister refused the application for the Permanent Visa on grounds unrelated to the applicant’s claim that he had been subjected to domestic violence. The applicant applied for review of that decision by the Administrative Appeals Tribunal (the Tribunal).

  8. A hearing took place before the Tribunal on 16 July 2018. It is apparent from a reading of the transcript of the Tribunal hearing that the Tribunal member had not, either prior to, or during the course of the Tribunal hearing, read documentation said to constitute “ … the two competent persons declaration …” as were required to be submitted under reg. 124(b) of Schedule 1 to the Migration Regulations 1994 (Cth) (the Regulations). [1] That documentation had been sent by letter to the Department in 2014. Upon the applicant’s representative asking for time to provide such documentation to the Tribunal, the Tribunal member gave leave to the applicant’s representative to provide such documentation to the Tribunal by the close of business that day. 

    [1]           See in particular pp. 11 – 14 of Transcript of Tribunal hearing – annexure GN-1 to the affidavit of Mr

  9. At 11.14 am on 16 July 2018, the applicant’s lawyers caused an email to be sent to the Registry of the Tribunal. Attached to such email was a medical report of one Dr Kirat Parikh and a statutory declaration of a social worker named Hakakhe Ganyu.

  10. On 17 July 2018, the Tribunal affirmed the decision of the delegate to refuse to grant the visa on the basis that no claim of family violence had relevantly been made under the regulations. At [10] – [13] of its reasons, the Tribunal found as follows:

    “Has a claim of family violence been made under the regulations?

    [10]In this case there is no claim (or evidence) of judicially determined family violence

    [11]The Tribunal advised the applicant that further to his claim of suffering family violence, the applicant is required to provide the necessary evidence in order to establish a valid claim for family violence under Regulation 1.24(b) of the Migration Act.

    [12]The applicant has provided the Tribunal (folios 31-36 (CLF2016/23438)) with a Statutory Declaration (in regards to his claim of having suffered family violence) as required under the legislation. A ‘To whom it may concern’ letter dated 11 October 2014 from Dr Vu Le (folio 54 (CLF2016/23438)), and a report from Dr Kirit Parikh dated 2 October 2014 (Tribunal file 1606059), have also been provided. Each is acceptable as a medical report (Type of Evidence) as specified under Schedule 1, though only one of each type of evidence may be presented for the purposes of paragraph 1.24(b). A letter (at folio 30 (CLF2016/23438)) from Felicity Neill (Initial Assessment and Planning worker) for the Salvation Army Social Housing Service does not meet the minimum requirements of any of the ‘Types of Evidence’ specified in Schedule 1 (IMMI 12/116) as it doesn’t contain any of the three ‘details’ specified in Schedule 1 as is required of a letter or assessment report made by a refuge or crisis centre. A Statutory Declaration from a member of the Australian Association of Social Workers has been provided (on the Tribunal file (and including previously to the Department) at folios 59(reverse)-55). At point 1 the Social Worker states, “Joseph requested for this statutory declaration which outlines he accounts of, the specific details of relevant family violence, impact on the visa applicant and my professional opinion based on my interview of the applicant’s claims as victim of relevant family violence.” It is clear from this Statutory Declaration that the Social Worker was not engaged to provide counselling or assistance per se, but rather a statutory declaration for the sole purpose of making a family violence claim. Accordingly, the statutory declaration provided by the Social Worker was not one provided in which that worker “…provided counselling or assistance to the alleged victim while performing the duties of a social worker”, as is required. Accordingly, it is not a ‘Type of Evidence’ as specified under the instrument.

    [13]As there is no other documentary evidence currently before the Tribunal which meets the legislative requirements, it follows that the Tribunal has no alternative but to find that a valid non-judicially determined family violence claim has not been made by the applicant as only one ‘Type of Evidence’ (which meets the requirements) has been provided to the Tribunal, in addition to the applicant’s Statutory Declaration.”

  11. Notice of the decision of the Tribunal was sent to the applicant by letter dated 18 July 2018. An Originating Application for Review of the decision of the delegate was filed on 6 August 2018.

    Grounds of Review

  12. At the time of the hearing before the Court, the applicant relied upon a Further Amended Application for Review, the grounds of which were as follows:

    1.“The Tribunal failed to comply with s 360 of the Migration Act 1958 (Act) by failing to give the Applicant a meaningful hearing relating to the issues arising in relation to the decision under review- namely, that the statutory declaration declared by registered social worker, Halakhe Ganyu, dated 29 September 2016 did not comply with the terms of legislative instrument IMMI 12/116 and thereby did not comply with regulation l.24(b) of the Migration Regulations 1994 (Cth) (Regulations).

    PARTICULARS

    a.In support of a claim that he had suffered family violence committed by his former sponsoring partner for the purposes of cl 801.221( 6) of the Regulations, the Applicant provided a statutory declaration declared by registered social worker, Halakhe Ganyu, dated 29 September 2016 (social worker declaration): CB351.

    b.The delegate of the First Respondent in the decision under review refused the Applicant's visa application on a different basis, and did not consider the terms and effect of IMMI 12/116: CB400.

    c.The Tribunal found that "the Social Worker was not engaged to provide counselling or assistance per se, but rather a statutory declaration for the sole purpose of making a family violence claim": at [12], CB500.

    d.On this basis, the Tribunal found that the social worker declaration was "not a 'Type of Evidence as specified under the instrument' (at [12], CB500) and therefore that the applicant had not made either a valid judicially determined or non-judicially determined claim of suffering family violence in accordance with regulation 1.23 of the Regulations (at [17], CB501).

    e.That issue was the sole dispositive issue arising in relation to the decision under review.

    f.The Tribunal failed to put that proposition to the applicant for comment or to provide a meaningful opportunity for her to give evidence and present arguments in relation to that issue at the hearing before the Tribunal on 16 July 2018.

    g.In the premises, the Tribunal failed to comply withs 360 of the Act.

    1A. The Secretary failed to comply with s 352(4) of the Act by failing to provide the social worker declaration to the Tribunal in a way that affected the Tribunal's exercise of jurisdiction.

    PARTICULARS

    a.At the time of the Tribunal hearing on 16 July 2018, the Tribunal had not sighted the social worker declaration, and did not know whether the social worker declaration formed part of the file before it.

    b.Immediately after the hearing, on 16 July 2018, the Applicant's representative submitted documents (including the social worker declaration) to the Tribunal over the counter at the Tribunal's registry.

    c.Later on 16 July 2018, the Applicant's representative submitted documents (including the social worker declaration) by email to the Tribunal.

    d.It is to be inferred from particulars A-C above that the social worker declaration did not form part of the material provided to the Tribunal by the Secretary.

    e.In the premises the Secretary contravened s 352(4) of the Act.

    f.Had the Secretary not contravened the Act, it is reasonably likely that the Tribunal hearing on 16 July 2022 would have proceeded differently.

    g.In the premises, the Secretary's contravention of the Act compromised the Tribunal's decision-making process in such a way that the Tribunal's decision was affected by jurisdictional error.

    2.In purporting to discharge its function, the Tribunal reasoned illogically or irrationally and thereby committed jurisdictional error by its approach to the question of whether the social worker declaration complied with the terms of IMMI 12/116.

    PARTICULARS

    a.IMMI 12/116 provided that evidence acceptable for the purposes ofreg l.24(b) of the Regulations included a "Statutory declaration made by ... a member of the Australian Association of Social Workers ... who has provided counselling or assistance to the alleged victim while performing the duties of a social worker".

    b.The sole basis for the Tribunal's conclusion that the social worker was not engaged to provide counselling or assistance (see Particular B to ground 1) and consequently that the social worker declaration did not comply with IMMI 12/116 was because it said "Joseph requested for this statutory declaration which outlines he accounts of, the specific details of relevant family violence, impact on the visa applicant and my professional opinion based on my interview of the applicant's claims as victim of relevant family violence": at [12], CB500.

    c.The statement of the social worker was not a probative or logically sound basis for the Tribunal's conclusion.

    d.In the premises, the Tribunal reasoned illogically or irrationally and thereby committed jurisdictional error.”

  13. As was submitted on behalf of the applicant, the sole ground on which the Tribunal affirmed the decision of the delegate was that a compliant claim of family violence had not been made. Though the Tribunal found that the medical report prepared by Dr Parikh was complaint, it did not accept that the statutory declaration made by the social worker named Ganyu was compliant. The Tribunal found that the statutory declaration did not evidence that Ganyu had relevantly “ … provided counselling or assistance to the alleged victim while performing the duties of a social worker.” as was required under IMMI 12/116 (Ministerial Instrument).  

  14. Central to a consideration as to whether the Ganyu statutory declaration was compliant or not was an appreciation of both the context in which the statutory declaration was obtained, as well as the content of the declaration.

  15. First, it is to be noted that the statutory declaration was intended to be dated 29 September 2014 (though the date on page 8 of the statement appears to be “29 September 2016”, the declaration was attached to correspondence sent to the Department by letter and email respectively dated 21 October 2014 and 22 October 2014). [2] In such circumstance, it could not be said that the statutory declaration had been forensically obtained immediately prior to the decision of the delegate which was made on 15 April 2016, or immediately prior to the Tribunal hearing which was conducted on 16 July 2018.

    [2]           See pp. 347 – 358 inclusive of Court Book (CB).

  16. Secondly, there was no evidence before the Court that the Secretary to the Department had provided either the Ganyu declaration or the Parikh report to the Tribunal prior to the hearing. Notwithstanding that the applicant’s representative had squarely raised the existence of such documents with the Tribunal member during the course of such hearing, the Court infers, because the Tribunal member made no reference to their knowledge of the existence of either such document during the course of the Tribunal hearing, that the Tribunal was not in possession of either such document until after their provision to the Tribunal by email at or about 11.14 am shortly after the Tribunal hearing that day. As was pointed out by Counsel for the applicant, no affidavit evidence clarifying the issue as to whether such material was provided to the Tribunal was ever filed on behalf of the first respondent.

  17. One would have expected that in circumstances where the Tribunal identified during the hearing that it was in possession of one “competent persons declaration” [3] – the Court infers that the rejected letter of Felicity Neill as being non-compliant (as referred to at [12] of the reasons of the Tribunal) was that document – it would have also identified that it was in possession of the Ganyu declaration and the Parikh report had that been the case. Such documents were a necessary pre-requisite for the granting of the visa in circumstances where the spousal relationship had ceased, and where the applicant was alleging that he had been subjected to family violence.

    [3]           See Transcript page 10 at lines 1 – 17.

  18. Third, a reading of the Ganyu statutory declaration reveals the following:

    (a)Ganyu satisfied the requirement of being a member of the Australian Association of Social Workers.

    (b)It was recorded [4] that during a counselling interview conducted on 19 September 2014 (some 10 days prior to the date of execution of the statutory declaration), the applicant had provided information regarding his family violence experiences. It is noteworthy that the nature of such contact was referred to in the body of the statutory declaration as having been conducted in a counselling context. Such claim was not contradicted. Counselling was relevantly one requirement going to compliance under IMMI 12/116.

    (c)After its receipt of the Ganyu declaration and the Parikh report, the Tribunal did not reconvene for the purpose of further clarifying with either the applicant or Ganyu the basis on which they first met, and whether counselling did or did not take place. In such circumstances, there was no basis for the finding, at [12] of its reasons, that “ … the social worker was not engaged to provide counselling or assistance per se …”, or that no counselling took place. It is trite that a person may be professionally counselled on one, or on more than one occasion. IMMI 12/116 does not relevantly provide that there must be more than one occasion of counselling to have occurred before a social worker is able to relevantly make a compliant statutory declaration. Had that been the intention of the Minister, one would have thought that such requirement would have been specifically set out in the body of IMMI 12/116.

    (d)Under the heading “Impact of Domestic Violence on the Applicant”, Ganyu concluded that the applicant had suffered adverse physical, psychological and emotional affects as a result of family violence. Such opinion was said to have been gained during “interviews” conducted with him. The fact that the statutory declaration made reference to more than one interview having been conducted was another reason why the Tribunal erred in failing to reconvene to further question the applicant, or Ganyu, as to the circumstances in which the counselling interview/interviews took place.

    (e)It was submitted on behalf of the applicant that the requested provision by Ganyu of the statutory declaration was in itself “assistance” able to be provided by a social worker which fell under IMMI 12/116. The Court does not accept such submission on the basis that the assistance contemplated by the Ministerial instrument was professional assistance, rather than administrative assistance. It is arguable, though, that merely by conducting an interview with the applicant, Ganyu was providing professional assistance by allowing the applicant to tell his story openly to a professional who was qualified and well able to assess the veracity of what was being said to them. It is of note that Ganyu held the degree of a Bachelor of Social Work, and a Masters of Social Work.

    [4]           Dot point 4 at p. 351 of CB.

  1. It was submitted on behalf of the First Respondent that the Court ought to follow decisions of Judges of this Court in Dang v Minister for Immigration & Anor [2016] FCCA 1426 and Thaworn v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2021] FCCA 2133, and that the Court was bound by the judgment of Middleton J in Pham v Minister for Immigration and Border Protection [2018] FCA 1946. The Court does not accept such submissions, and finds that each of those cases were factually distinguishable from the present.

  2. The question in Dang was whether statutory declarations from a psychologist and social worker evidenced the provision of treatment or counselling to an applicant. It is clear on the face of the Ganyu declaration that at least one interview was conducted in a counselling interview context.

  3. The question in Thaworn was whether the Tribunal had overlooked certain evidence before it. At [30]-[32] inclusive of his reasons, His Honour Judge Young found as follows:

    “[30] That is to be contrasted with both the social worker and the psychologist in this case. There is evidence, essentially unchallenged, that the applicant visited the social worker on multiple occasions, three I believe the applicant said. There is also evidence the social worker gave a referral for the applicant to see a psychologist, Ms Stathis. I note I used the word “referral”, however, the applicant used the words “advised me”. In substance, it is a referral to a psychologist from the social worker that in my view would constitute assistance of the kind referred to in IMMI 12/116. That was approved by Middleton J in Pham.

    [31]The Tribunal member, in considering whether or not the requirements of IMMI 12/116 were satisfied, concluded that the psychologist’s report was created merely for provision to the Tribunal and that the social worker’s report did not involve counselling or assistance. These conclusions appear to ignore the evidence of the applicant that she was consulting both the social worker and psychologist because of her mental state and the applicant’s evidence that the social worker referred her to the psychologist. That, in my view, is indicative of a social worker engaged in counselling or assistance and a psychologist engaged in a therapeutic approach to the applicant. This is notwithstanding that the psychologist’s report does not detail the form of therapy given, though that is not required in IMMI 12/116.

    [32]I am satisfied that the Tribunal member has overlooked crucial and potentially determinative evidence or has misdirected herself about the requirements of IMMI 12/116. I am unable to say which. In any event, I am satisfied that the result is jurisdictional error.”

  4. The Court similarly finds that the Tribunal in the present matter overlooked the content of the Ganyu report where it specifically referred to a counselling interview having been conducted on 19 September 2014, and further where an opinion was expressed by Ganyu in the context of the conduct of interviews, as opposed to the conduct of only one interview.

  5. When construing Ministerial instruments such as IMMI 12/116, the Court finds that in the absence of any confining or restrictive language which narrows or confines the interpretation of a word or words, such word or words ought to be given their primary and natural meaning. The absence of any stated intention for the words “counselling or assistance” to be construed as constituting more than one occasion of counselling or assistance, or a demonstrated course of ongoing counselling or assistance, is, with respect, suggestive of such narrow approach being inapt.

  6. The Court finds that Grounds 1 and 1A of the Further Amended Application for Review have been made out. Under s. 360 of the Migration Act 1954 (Cth) (the Act), the Tribunal ought to have appreciated that the nature of the interaction between the applicant and Ganyu was a live issue, and that such issue could not be properly the subject of findings by the Tribunal unless the applicant had been given an opportunity to advise the Tribunal as to the nature, number and extent of contact had between him and Ganyu. The Tribunal made erroneous findings in circumstances where it failed to carry out its statutory obligation to invite the applicant to appear before the Tribunal to give evidence and present arguments relating to live issues. As was said in Szbel v Minister for Immigration and Multicultural and Indigenous Affairs (2005) 228 CLR 152 at [35]:

    “[35]The Tribunal is not confined to whatever may have been the issues that the delegate considered.  The issues that arise in relation to the decision are to be identified by the Tribunal.  But if the Tribunal takes no step to identify some issue other than those that the delegate considered dispositive, and does not tell the applicant what that other issue is, the applicant is entitled to assume that the issues the delegate considered dispositive are "the issues arising in relation to the decision under review".  That is why the point at which to begin the identification of issues arising in relation to the decision under review will usually be the reasons given for that decision.  And unless some other additional issues are identified by the Tribunal (as they may be), it would ordinarily follow that, on review by the Tribunal, the issues arising in relation to the decision under review would be those which the original decision‑maker identified as determinative against the applicant.”

  7. In Nathanson v Minister for Home Affairs [2022] HCA 26 (17 August 2022) at [30] – [33] inclusive, Kiefel CJ, Keane and Gleeson JJ found as follows:

    “[30]In Hossain v Minister for Immigration and Border Protection, a majority comprising Kiefel CJ, Gageler and Keane JJ enunciated a common law principle of statutory interpretation. That principle is that a statute conferring decision-making authority is "ordinarily to be interpreted as incorporating a threshold of materiality in the event of non-compliance". It is well recognised that, generally speaking, legislation should be construed to discourage unnecessary litigation, to reduce wasting time and cost and to preserve the dignity of the law. And, in particular, in relation to the Act, this Court has declined to attribute to the legislation the impractical intention that an error in process, which cannot have affected the outcome of the process, requires that the process be repeated.

    [31]In MZAPC, a majority comprising Kiefel CJ, Gageler, Keane and Gleeson JJ explained the evolution of the contemporary understanding of jurisdictional error that supported that principle of interpretation. Their Honours further explained:

    "The principle accommodates determination of the limits of decision-making authority conferred by statute to the reality that '[d]ecision-making is a function of the real world' by distinguishing the express and implied statutory conditions of the conferral from the statutory consequences of breach and by recognising that the legislature is not likely to have intended that a breach that occasions no 'practical injustice' will deprive a decision of statutory force."

    [32]As explained in MZAPC, the materiality of a breach requires consideration of "the basal factual question of how the decision that was in fact made was in fact made". This question is determined by proof of historical facts on the balance of probabilities. Then, it is necessary to consider whether the decision that was in fact made could have been different had the relevant condition been complied with "as a matter of reasonable conjecture within the parameters set by the historical facts that have been determined". The burden falls on the plaintiff to prove "on the balance of probabilities the historical facts necessary to enable the court to be satisfied of the realistic possibility that a different decision could have been made had there been compliance with that condition".

    [33]There will generally be a realistic possibility that a decision-making process could have resulted in a different outcome if a party was denied an opportunity to present evidence or make submissions on an issue that required consideration. The standard of "reasonable conjecture" is undemanding. It recognises that a fundamental purpose of affording procedural fairness is to afford an opportunity to raise relevant matters which are not already obvious, or not liable to be advanced by the apparently persuasive "story" of the opposing party. Where a Tribunal errs by denying a party a reasonable opportunity to present their case, "reasonable conjecture" does not require demonstration of how that party might have taken advantage of that lost opportunity. Nothing said in MZAPC denies this. To the contrary, the standard of "reasonable conjecture", correctly applied, proceeds on assumptions that are derived from the rationale for procedural fairness, namely that, if given a fair opportunity to present their case, a party will take advantage of that opportunity and that, by doing so, the party could achieve a favourable outcome.”

  8. The Court finds that the Tribunal hearing was not conducted in such a way as to afford procedural fairness to the applicant. The Tribunal made findings in circumstances where it ought to have first reconvened and sought further clarification from the applicant about a live issue which was ultimately, and erroneously, dispositive.

  9. The guiding principle of fairness requires the granting of the Further Amended Application for Review. In the light of the above reasons, it is unnecessary for the Court to deal with Ground 2 of such application for review.

  10. The Tribunal fell into jurisdictional error and was procedurally unfair. The decision of the Tribunal is quashed.

  11. The Court will hear the parties as to costs.

I certify that the preceding twenty-nine (29) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Egan.

Associate:

Dated: 15 November 2022     


            Nwankwo filed on 22 July 2022.
Actions
Download as PDF Download as Word Document