Patel v Minister for Home Affairs
[2019] FCCA 600
•22 February 2019
FEDERAL CIRCUIT COURT OF AUSTRALIA
| PATEL & ORS v MINISTER FOR HOME AFFAIRS & ANOR | [2019] FCCA 600 |
| Catchwords: MIGRATION – Regional Employer Nomination (Class RN) (subclass 187) Visa Application – review of a decision of the Administrative Appeals Tribunal – no nomination in place – ability to review nomination decision – no jurisdictional error – application dismissed. |
| Legislation: Migration Act 1958 (Cth), ss.359A, 359B, 359C, 363, 379A, 379G, 476(1) Migration Regulations 1994 (Cth), sch.2, cl.187.233, reg.4.17(4) |
| Cases cited: AZAEY v Minister for Immigration & Border Protection [2015] FCAFC 193 |
| First Applicant: | SANDIPKUMAR KANTIBHAI PATEL |
| Second Applicant: | HETALBEN SANDIPKUMAR PATEL |
| Third Applicant: | KASHISH PATEL |
| First Respondent: | MINISTER FOR HOME AFFAIRS |
| Second Respondent: | ADMINISTRATIVE APPEALS TRIBUNAL |
| File Number: | PEG 221 of 2018 |
| Judgment of: | Judge Kendall |
| Hearing date: | 22 February 2019 |
| Date of Last Submission: | 22 February 2019 |
| Delivered at: | Perth |
| Delivered on: | 22 February 2019 |
REPRESENTATION
| Applicants: | The First Applicant in person and on behalf of the Second Applicant and as litigation guardian of the Third Applicant |
| Counsel for the First Respondent: Second Respondent: | Ms E. Tattersall Submitting appearance, save as to costs |
| Solicitors for the Respondents: | Sparke Helmore Lawyers |
ORDERS
The application be dismissed.
The first and second applicants pay the first respondent’s costs fixed in the amount of $5,000.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT PERTH |
PEG 221 of 2018
| SANDIPKUMAR KANTIBHAI PATEL |
First Applicant
| HETALBEN SANDIPKUMAR PATEL |
Second Applicant
| KASHISH PATEL |
Third Applicant
And
| MINISTER FOR HOME AFFAIRS |
First Respondent
| ADMINISTRATIVE APPEALS TRIBUNAL |
Second Respondent
REASONS FOR JUDGMENT
(Ex Tempore; Revised from Transcript)
Introduction
By application filed in this Court on 23 April 2018, the applicants seek judicial review of a decision of the Administrative Appeals Tribunal (the “Tribunal”) dated 4 April 2018.
The Tribunal’s decision affirmed a decision of a delegate of the Minister for Home Affairs (the “Minister”) not to grant the applicants a Regional Employer Nomination (Class RN) (subclass 187) visa (the “visa”).
This proceeding is brought pursuant to s.476(1) of the Migration Act 1958 (Cth) (the “Act”). To obtain assistance from the Court, the applicants must show jurisdictional error on the part of the Tribunal.
The applicants were not legally represented before the Court. The first applicant, Mr Patel, spoke on behalf of the second applicant (his wife) and the third applicant (his child).
The third applicant, a minor, participates in these proceedings by her litigation guardian, Mr Patel, pursuant to the Court’s orders dated 20 June 2018.
Ms Tattersall appeared on behalf of the Minister. The Court had before it a Court Book (“CB”) numbering 104 pages. The Court also received written submissions from the Minister dated 31 January 2019. No written submissions were received from the applicants.
Factual Background
The Court has reviewed the factual outline provided by the Minister and adopts as its own the factual background outlined at [3]-[17] in the Minister’s written submissions. This summary was not disputed and provides, relevantly, as follows.
On 8 September 2015, Mr Patel lodged an application for the visa in relation to the nominated position of “Personal Assistant” (CB 1-23).
The second applicant and the third applicant were included in the application as members of Mr Patel’s family unit (CB 3-5).
The authorised recipient listed on the visa application was Mr Derrick Peters, the director of Dreamland (Australia) Pty Ltd ATF the Peters Family Trust (“Dreamland”), who had nominated Mr Patel (CB 7-8).
Dreamland was a migration services agency. Mr Peters was a registered migration agent (CB 64).
On 5 April 2016, a Ministerial delegate invited the applicants to comment on information that the nomination submitted to the Minister’s Department by Dreamland had been refused (CB 31-34).
The delegate advised that, because the nomination had been refused, he would have no choice but to refuse the visa if the applicants did not withdraw their application (CB 31).
No response was provided by the applicants or their representative.
On 17 May 2016, the same delegate refused to grant the visa on the basis that the applicants did not meet cl.187.233 of the Migration Regulations 1994 (Cth) (the “Regulations”) – in effect, because the nomination lodged by Dreamland “had not been approved” (CB 38-41).
On 19 May 2016, the applicants applied to the Tribunal for review of the delegate’s decision in that regard (CB 42-44).
A copy of the delegate’s decision was attached to the review application before the Tribunal. Mr Peters, arguably in his capacity as a migration agent, was listed as the applicants’ representative.
On 21 March 2017, the Tribunal wrote to the applicants inviting them to attend a hearing before it to give evidence and present arguments (CB 61-63).
On 22 March 2017, the applicants responded to the hearing invitation, indicating that they would attend, as would Mr Peters (CB 64-67).
The Tribunal hearing record indicates that the nomination hearing and the applicants’ visa hearing were held together on 29 March 2017 (CB 68-72).
On 13 March 2018, the Tribunal affirmed the delegate’s decision to refuse Dreamland’s nomination application (the “nomination decision”) (CB 76-90). Relevantly, the Tribunal, addressing Dreamland’s nomination, found:
82.Based on the evidence before me I am not satisfied that the business is financially capable of employing a full time employee who will be paid $60,000 per year. As a result, the Tribunal is not satisfied that the applicant will be able to employ the nominee in the nominated position from the time of visa grant for at least two years fulltime. Accordingly, the requirement in r.5.19(4)(d) is not met.
83.As the Tribunal find that the applicant does not meet r.5.19(4)(d) it is not necessary to make findings whether the business meets r.5.19(4)(h)(ii)(A) which requires that the position is located in ‘regional Australia’.
84.For the above reasons the Tribunal is not satisfied that the applicant meets the requirements of r.5.19(4). The applicant has not sought to satisfy the criteria in the Temporary Residence Transition nomination stream, and as such has not met the requirements in r.5.19(3). Accordingly, the nomination of the position cannot be approved. Therefore, the Tribunal must affirm the decision under review.
85.The Tribunal affirms the decision under review to refuse the nomination.
On 14 March 2018, the Tribunal invited the applicants to comment on certain information (CB 91-94) as follows:
Your visa application was refused by the Department on 17 May 2016 because the appointment, to which the visa application relates, has not been approved by the Department.
The decision not to approve nomination by Dreamland (Australia) Pty Ltd ATF The Peters Family Trust was made by the Department on 5 April 2016.
Dreamland (Australia) Pty Ltd ATF The Peters Family Trust applied for review of this decision at this Tribunal on 12 April 2016. On 13 March 2018, the Tribunal affirmed the primary decision related to the nomination application.
This information, if accepted and relied upon by the Tribunal, would be the reason or part of the reason for the Tribunal to affirm the decision made by the Department to refuse you the grant of a subclass 187 visa. This is because one of the criteria contained within subclass 187, namely clause 187.233(3) requires that the Minister has approved the nomination.
If the Tribunal were to rely on this information, the Tribunal would accordingly be required to affirm the decision of the delegate on the basis that you do not meet the criteria contained within clause 187.233.
This information is relevant to the second and the third named review applicants because cl.187.311 which prescribes that the secondary applicants meet the requirement of this subclause if the applicants are members of the family unit (the primary applicant) who holds a Subclass 187 visa granted on the basis of satisfying the primary criteria for the grant of the visa and they made a combined application with the primary applicant.
Accordingly, if the first named review applicant is not a holder of a subclass 187 visa, the secondary applicants will not be able to meet cl.187.311.
On 22 March 2018, Mr Patel telephoned and emailed the Tribunal. He indicated that he was no longer employed by Dreamland and requested that all correspondence from the Tribunal be sent to him (CB 95-96).
On 22 March 2018, the Tribunal sent Mr Patel the correspondence containing the invitation to comment that had been sent to Mr Peters on 14 March 2018 (CB 97).
The applicants did not respond to this invitation.
On 4 April 2018, the Tribunal affirmed the decision of the delegate not to grant visa (CB 99-104).
The Tribunal’s Decision
The Court notes and adopts the Minister’s summary of the Tribunal’s decision at [18]-[28] in his written submissions. This is an accurate summary and, otherwise as amended below, provides as follows.
The Tribunal began with an overview of the history relevant to the applicants’ visa application and the relevant visa criteria as follows. That summary provides (CB 101-102):
2.The applicants applied for the visas on 8 September 2015. At the time of application, Class RN contained one subclass: Subclass 187 (Regional Sponsored Migration Scheme).
3.The criteria for a Subclass 187 visa are set out in Part 187 of Schedule 2 to the Migration Regulations 1994 (the Regulations). The primary criteria must be satisfied by at least one applicant. Other members of the family unit, if any, who are applicants for the visa need satisfy only the secondary criteria. Applicants seeking to satisfy the primary criteria must meet the ‘Common criteria’, as well as the criteria of one of three alternative visa streams: the Temporary Residence Transition stream, the Direct Entry stream, or the Agreement stream.
4.In the present case, the first named applicant (the applicant) is seeking the visa in the Direct Entry stream, to work in the nominated position of a Personal Assistant. This stream is designed for persons who have never, or have only briefly worked in the Australian labour market and are applying for the visa outside Australia, or are applying from inside Australia but are not eligible for the Temporary Residence Transition stream.
5.The related nomination application referred to in the visa application had been refused by the department and, as a result, the delegate found that the applicant did not meet cl.187.233.
6.The applicants applied to this tribunal for review of the Department’s decision on 19 May 2016 and with their application provided a copy of the primary decision record. The applicants were represented in relation to the review by their registered migration agent.
7.By letter dated 14 March 2018, and in accordance with section 359A of the Act, the tribunal invited the applicants to comment on or respond to information that it considered would be the reasons, or part of the reason, for affirming the decision under review. […]
8.The invitation was sent to the applicants’ nominated address provided in connection with the review and advised that, if the comments on or response to information was not provided in writing by 28 March 2018, and no extension of time to provide comments on or response to information was requested or granted, the tribunal may make a decision on the review without taking further steps to obtain the comments on or response to information and the review applicants would lose any entitlement they might otherwise have had under the Act to appear before the tribunal to give evidence and present arguments.
9.On 22 March 2018, the first named applicant requested that all correspondence be sent to his address.
The Tribunal then noted that the applicants had been invited, pursuant to s.359A of the Act, to comment on, or respond to, information that it considered would be the reason, or part of the reason, for affirming the delegate’s decision (CB 101-102 at [7]).
The Tribunal noted that no response had been received (CB 102 at [10]).
The Tribunal then considered whether it should adjourn the review to allow the applicants additional time in which to provide their comments or response to the information contained in the s.359A invitation (CB 102 at [11]).
The Tribunal took into account relevant case law, which provided that the Tribunal was not required to indefinitely defer its decision-making processes, and the reasonableness of any request for an adjournment and noted that the applicants had not provided a response within the prescribed period (CB 102):
12.[…] [T]he tribunal has taken into account the decisions in Huo v Minister for Immigration and Multicultural Affairs and Manna v Minister for Immigration and Citizenship where the Courts have held that the tribunal is not required to indefinitely defer its decision-making processes. It has also had regard to the decision in Minister for Immigration and Citizenship v Li regarding the reasonableness of any request for an adjournment, and the Full Federal Court decision in Minister for Immigration and Border Protection v Singh which considered this issue, as well as the more recent decision in Kaur v Minister for Immigration and Border Protection where analogous issues were discussed.
13.In this case the tribunal wrote to the applicants under subsection 359A of the Act inviting them to provide comments and/or or response to the tribunal letter of 14 March 2018. The tribunal notes that the applicants have had the benefit of representation from a registered migration agent to assist with their review applications. Yet, neither the applicant nor their representative provided comments on or response to information within the prescribed periods set for this purpose.
(Footnotes omitted)
The Tribunal had regard to the fact that the visa application was refused due to the applicants’ inability to meet cl.187.223 of Schedule 2 to the Regulations (ie, because the position to which the application related had not been approved at the time of the delegate’s decision) (CB 103 at [14]).
The Tribunal noted that if the applicants were not granted the visa, they might be required to depart Australia. It also noted that there was nothing to prevent the applicants from re-applying for the visa once the Minister had approved the nomination of the position to which the application related (CB 103 at [15]).
The Tribunal stressed that the applicants had had sufficient time in which to address the central issues arising in the application for review and a fair opportunity to provide their comments on, or response to, the information contained in the Tribunal letter dated 14 March 2018 which the applicants had received (CB 103 at [16]).
Accordingly, the Tribunal decided that it was reasonable to exercise its discretion under sub-s.363(1)(b) of the Act not to further adjourn the review and to proceed with its decision without taking further steps to obtain the comments on, or response to, information contained in the Tribunal’s letter dated 14 March 2018 (CB 103 at [16]-[17]).
The Tribunal then set out the requirements of cl.187.233 of the Regulations (CB 103 at [18]-[19]).
Importantly, the Tribunal found that, based on the evidence before it, the nomination mentioned in cl.187.233, lodged by Dreamland on behalf of Mr Patel, had not been approved at the time of the Tribunal’s decision (CB 103 at [20]).
As a result, the Tribunal found that the Mr Patel did not meet the requirements of cl.187.233 at the time of its decision (CB 103 at [20]).
The Tribunal found that, as the second applicant and the third applicant did not meet the secondary criteria, it was also required to affirm the decision in respect of their applications (CB 104 at [22]-[23]). In effect, this meant that the applicants were denied the visa they were requesting.
Proceedings in this Court
The applicants filed an application for judicial review in this Court on 23 April 2018 seeking a final order that the decision of the Tribunal be quashed.
The applicants rely on three grounds of review:
1.The Tribunal made a jurisdictional error in finding that the First Applicant does not meet the criteria clause 187.233 of Schedule 2 to the Regulations.
a.A jurisdictional error was made by the Tribunal in refusing the related nomination application referred to in the visa application.
b.At [80] of the Tribunal’s decision record in respect of the appeal of the refused nomination application, the Tribunal refused to consider the nominating employer’s access to personal cash reserves as an indication of the nominating business’ capacity to employ the First Application on a full-time basis for at least two years.
c.The Tribunal made a jurisdictional error in failing to take the employer’s personal cash reserves into consideration when determining the nominating employer’s capacity to pay the First Applicant for the purposes of sub-regulation 5.19(4)(d)(i) of the Migration Regulations.
d.This jurisdictional error resulted in an incorrect finding that the First Application did not have an approved nomination and thus does not satisfy the criteria for clause 187.233 of Schedule 2 to the Regulations.
e.The Applicants seek to have these decisions reviewed.
2.The Tribunal made a jurisdictional error in finding that an adjournment of review should not be granted under subsection 363(1)(b) of the Migration Act to allow the applicant additional time to provide further evidence to support their review applications.
3.The Tribunal made a jurisdictional error to proceed to decision without taking further steps to obtain comments on or a response to the information contained in the Tribunal’s letter of 14 March 2018.
No written submissions were provided by the applicants. This is despite an order by a Registrar of this Court which allowed them to do so.
To be successful, the applicants must demonstrate to the Court that the Tribunal’s decision was affected by jurisdictional error.
The Court noted that Mr Patel, on behalf of the second applicant and the third applicant, was not legally represented and did not appear to have received any legal assistance in relation to the judicial review application before this Court.
In this context, and noting the comments of Justice Colvin in DQQ17 v Minister for Immigration & Border Protection [2018] FCA 784 at [8] in relation to the need to assist unrepresented applicants whenever possible, the Court explained to Mr Patel that the possible categories of jurisdictional error are not exhaustive and may sometimes overlap. It was explained that for migration decisions of this sort they most commonly include the following categories:
a)where the decision-maker identifies the wrong issue or asks the wrong question (see Craig v State of South Australia (1995) 184 CLR 163 (“Craig”) at 198);
b)where the decision-maker ignores relevant material (see Craig at 198);
c)where the decision-maker relies on irrelevant material (see Craig at 198);
d)where the decision-maker fails to follow mandatory procedures (see SAAP v Minister for Immigration & Multicultural & Indigenous Affairs & Anor (2005) 228 CLR 294 at [207]-[208]);
e)where the decision-maker shows actual or apprehended bias (see SZRUI v Minister for Immigration, Multicultural Affairs & Citizenship [2013] FCAFC 80 at [2]; AZAEY v Minister for Immigration & Border Protection [2015] FCAFC 193 at [16]-[17]); and
f)where the decision is illogical, irrational or unreasonable (see Minister for Immigration & Citizenship v SZMDS (2010) 240 CLR 611 (“SZMDS”) at [131]; Minister for Immigration & Citizenship v Li (2013) 249 CLR 332 (“Li”) at [26]-[28]; Minister for Immigration & Border Protection v Singh (2014) 231 FCR 437 at [44]) (“Singh”).
Mr Patel was also advised that the Court could not engage in “merits review” of the Tribunal’s decision as per the decision in Minister for Immigration and Ethnic Affairs v Wu Shan Liang (1996) 185 CLR 259.
The Court determined that Mr Patel understood what had been said to him and proceeded to hear the matter at hand.
Mr Patel was asked to outline what, in his opinion, he felt the Tribunal “did wrong”. To the extent that he was able to do so, his response is outlined below.
Consideration
Ground 1
The Tribunal made a jurisdictional error in finding that the First Applicant does not meet the criteria clause 187.233 of Schedule 2 to the Regulations.
a.A jurisdictional error was made by the Tribunal in refusing the related nomination application referred to in the visa application.
b.At [80] of the Tribunal’s decision record in respect of the appeal of the refused nomination application, the Tribunal refused to consider the nominating employer’s access to personal cash reserves as an indication of the nominating business’ capacity to employ the First Application on a full-time basis for at least two years.
c.The Tribunal made a jurisdictional error in failing to take the employer’s personal cash reserves into consideration when determining the nominating employer’s capacity to pay the First Applicant for the purposes of sub-regulation 5.19(4)(d)(i) of the Migration Regulations.
d.This jurisdictional error resulted in an incorrect finding that the First Application did not have an approved nomination and thus does not satisfy the criteria for clause 187.233 of Schedule 2 to the Regulations.
e.The Applicants seek to have these decisions reviewed.
In relation to ground 1, the Minister contended (at [32]-[34] in his written submissions):
a)ground one contains five particulars effectively pleading that the Tribunal made a jurisdictional error in the nomination decision for Dreamland on the basis that the Tribunal failed to consider the nominating employer’s access to Mr Peter’s, its director and sole share trader, personal cash reserves. Particular “e.” explicitly seeks review of the nomination application decision;
b)this ground is incompetent to the extent that it refers to the nomination decision; and
c)further, absent any application by Dreamland for orders setting aside the nomination decision or a finding that the nomination decision is flagrantly wrong and can be disregarded, the applicants remain unable to meet the criterion that they be subject to an approved nomination and their application is futile.
Mr Patel was asked to comment. Unfortunately, his response did not assist him in relation to the issues before this Court.
Mr Patel’s primary concerns relate to the nomination decision.
Unfortunately, the Court cannot assist Mr Patel or the other applicants in this matter. The Court agrees with the arguments advanced by the Minister in this regard.
As correctly emphasised by Ms Tattersall, Counsel for the Minister, the Tribunal was not required to review, or consider, the merits of the nomination filed by Dreamland. The issue for the Tribunal was whether the position to which the visa application related was the subject of an approved nomination.
Further, the applicants have no standing to seek judicial review of the nomination decision as they were not the “applicants in the review” in relation to that decision. Mr Patel is also no longer employed by Dreamland and has no standing in relation to the nomination or the decision that rejected it. Dreamland has not made an application for an order setting aside the nomination decision. As such, the Court currently has no jurisdiction in relation to that decision.
Here, the Tribunal relied upon the evidence that Mr Patel was no longer employed by the relevant nominee and the evidence that showed that the relevant nomination had not been approved.
Overall, the Tribunal considered the facts of the case, and the legislation it was required to examine. In the circumstances of this case, the Tribunal made a decision that was open to it. That decision was reasonably made: per Li.
Ground 1, accordingly, fails.
Grounds 2 and 3
2.The Tribunal made a jurisdictional error in finding that an adjournment of review should not be granted under subsection 363(1)(b) of the Migration Act to allow the applicant additional time to provide further evidence to support their review applications.
3.The Tribunal made a jurisdictional error to proceed to decision without taking further steps to obtain comments on or a response to the information contained in the Tribunal’s letter of 14 March 2018.
In relation to grounds 2 and 3, the Minister contends in his written submissions:
a)the Tribunal’s s.359A invitation dated 14 March 2018 complied with the relevant legislative requirements. It specified that the information was to be given in writing (s.359B(1) of the Act) by 28 March 2018, being the prescribed period of fourteen days from when the invitation was received (s.359B(2) of the Act read with reg.4.17(4) of the Regulations). The invitation was sent to the applicants’ authorised representative by email in accordance with ss.379A(5)(b) and 379G of the Act. Furthermore, the invitation was forwarded to the applicants on 22 March 2018 when the Tribunal was notified that the applicants’ representative was no longer acting for them;
b)as the applicants failed to provide the requested information before the expiry of the prescribed period, or seek an extension of time to respond, the Tribunal was entitled to proceed to make a decision without taking any further action to obtain the requested information from the applicants: s.359C(1) of the Act;
c)pursuant to s.363(1)(b), the Tribunal had the power to adjourn the review and defer making its decision. The Tribunal’s exercise of its discretion not to adjourn the review and to proceed to decision was reasonable in circumstances where Mr Patel had been on notice of the requirement of an approved nomination since 17 May 2016, had failed to respond to the s.359A invitation or to make any contact with the Tribunal in respect of same and in the absence of any evidence before the Tribunal that Mr Patel was subject to an approved nomination; and
d)there is nothing on the face of the Tribunal’s decision record to indicate that the Tribunal’s decision to exercise its discretion was arbitrary, capricious, without common sense or plainly unjust. The Tribunal’s decision to exercise its discretion was within the “area of decisional freedom” and that no jurisdictional error arises as a result.
Mr Patel was again asked to comment. Unfortunately, he was unable to address the concerns raised by the Minister. In effect, Mr Patel again expressed concern about the nomination decision. He says he was not afforded an opportunity to present accurate or complete information in relation to the nomination decision.
The Court agrees with the Minister in relation to the scope of what the Tribunal could and could not do in relation to the nomination decision and the exercise of its discretion. In effect, as indicated above, in relation to the Tribunal ultimately finding, the Tribunal did what it could do in circumstances where no employee nomination existed. There was no nomination in play and that limited, legislatively, what the Tribunal could and could not do to assist the applicants.
“Unreasonableness” can be inferred in circumstances where it is unclear how the decision-maker arrived at their decision not to exercise a discretionary power: Li at [76].
The applicant bears the onus of establishing the basis for drawing the inference necessary to make out the alleged jurisdictional error: Minister for Immigration & Citizenship v SZGUR (2011) 241 CLR 594 at [67].
A conclusion that the exercise of the discretionary decision-making power is unreasonable arises where the decision “lacks an evident and intelligible justification” (Li at [76]) and involves scrutiny of the factual circumstances in which the power comes to be exercised: Singh at [48].
Mr Patel was given an opportunity to present evidence and any decision in relation to an adjournment was made after a very clear assessment, on the evidence, of the opportunities that the applicants had been given. It cannot be said that the decision not to adjourn was unfair. It certainly does not amount to jurisdictional error. Overall, the decision to affirm the delegate’s decision was sound and open on the evidence before the Tribunal. Once it was clear to the Tribunal that the nomination in question had failed, that was, in effect, the end of the analysis available to it. The Tribunal had no discretion and was left in a position where it had no choice but to deny the applicants the visa.
Overall, in relation to “reasonableness” and whether the applicants should have been given greater opportunity to present evidence, it cannot be said here that the Tribunal acted unreasonably (as per Li) or in a way that is irrational or illogical (as per SZMDS).
For the reasons outlined above, grounds 2 and 3 fail.
Conclusion
Overall, the decision to affirm the delegate’s decision was sound and open on the evidence before the Tribunal. Once it was clear to the Tribunal that the nomination in question had failed and that the applicants had been given ample opportunity to prove otherwise, that was, in effect, the end of the analysis available to the Tribunal.
There is, in the circumstances of this case, no jurisdictional error demonstrated by the applicants’ three grounds of review. Accordingly, the Court finds that this application should be dismissed.
I certify that the preceding sixty-nine (69) paragraphs are a true copy of the reasons for judgment of Judge Kendall
Associate:
Date: 20 March 2019
Key Legal Topics
Areas of Law
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Administrative Law
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Immigration
Legal Concepts
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Judicial Review
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Natural Justice
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Procedural Fairness
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Jurisdiction
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