Pena Franco (Migration)

Pena Franco (Migration) [2019] AATA 4934 (13 November 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANTS:  Mr Jose Mauricio Pena Franco
Ms Nancy Lorena Sanchez Galindo
CASE NUMBER:  1817889
HOME AFFAIRS REFERENCE(S):           BCC2018/1242136
MEMBER:M. Edgoose
DATE:13 November 2019
PLACE OF DECISION:  Melbourne
DECISION:The Tribunal affirms the decision not to grant the applicants Student (Temporary) (Class TU) visas.

Statement made on 13 November 2019 at 8:53am
CATCHWORDS
MIGRATION – Student (Temporary) (Class TU) – Subclass 500 (Student) – genuine temporary stay – study will benefit salary in Colombia – personal ties to Colombia and Australia – economic circumstances are incentive to stay – gained experience in Australia – visa to maintain residence – decision under review affirmed

LEGISLATION
Migration Act 1958 (Cth), s 65
Migration Regulations 1994 (Cth), Schedule 2 cl 500.212

STATEMENT OF DECISION AND REASONS
APPLICATION FOR REVIEW

This is an application for review of a decision made by a delegate of the Minister for Home Affairs on 8 June 2018 to refuse to grant the applicants Student (Temporary) (Class TU) visas under s.65 of the Migration Act 1958 (the Act).
The applicants applied for the visas on 15 March 2018. At the time of application, Class TU contained two subclasses: Subclass 500 (Student) and Subclass 590 (Student Guardian). The primary visa applicant (the applicant) applied for the visa to undertake study in Australia and does not claim to meet the criteria for a Subclass 590 (Student Guardian) visa.
The delegate in this case refused to grant the visa on the basis that the applicant did not satisfy the requirements of cl.500.212 of Schedule 2 to the Migration Regulations 1994 (the Regulations) because the delegate was not satisfied that the applicant intends genuinely to stay temporarily in Australia.
The applicants appeared before the Tribunal on 28 October 2019 to give evidence and present arguments. The Tribunal hearing was conducted with the assistance of an interpreter in the Spanish and English languages.
The applicants were assisted in relation to the review by their registered migration agent.
For the following reasons, the Tribunal has concluded that the decision under review should be affirmed.
CONSIDERATION OF CLAIMS AND EVIDENCE
The criteria for a Subclass 500 (Student) visa are set out in Part 500 of Schedule 2 to the Regulations. The primary criteria in cl.500.211 to cl.500.218 must be satisfied by at least one applicant. Other members of the family unit, if any, who are applicants for the visa need only satisfy the secondary criteria. The issue in the present case is whether the applicant intends genuinely to stay in Australia temporarily.
Clause 500.212 requires as follows:
The applicant is a genuine applicant for entry and stay as a student because:
(a)the applicant intends genuinely to stay in Australia temporarily, having regard to:
(i)the applicant’s circumstances; and
(ii)the applicant’s immigration history; and
(iii)if the applicant is a minor—the intentions of a parent, legal guardian or spouse of the applicant; and
(iv)any other relevant matter; and
(b)the applicant intends to comply with any conditions subject to which the visa is granted, having regard to:
(i)the applicant’s record of compliance with any condition of a visa previously held by the applicant (if any); and
(ii)the applicant’s stated intention to comply with any conditions to which the visa may be subject; and
(c)of any other relevant matter.
Does the applicant intend genuinely to stay in Australia temporarily?
In considering whether the applicant satisfies cl.500.212(a), the Tribunal must have regard to Direction No.69, ‘Assessing the genuine temporary entrant criterion for Student visa and Student Guardian visa applications’, made under s.499 of the Act. This Direction, which is attached to this decision, requires the Tribunal to have regard to a number of specified factors in relation to:
·the applicant’s circumstances in their home country, potential circumstances in Australia, and the value of the course to the applicant’s future;
·the applicant’s immigration history, including previous applications for an Australian visa or for visas to other countries, and previous travel to Australia or other countries;
·if the applicant is a minor, the intentions of a parent, legal guardian or spouse of the applicant; and
·any other relevant information provided by the applicant, or information otherwise available to the decision maker, including information that may be either beneficial or unfavourable to the applicant.
The Direction indicates that the factors specified should not be used as a checklist but rather, are intended only to guide decision makers when considering the applicant’s circumstances as a whole, in reaching a finding about whether the applicant satisfies the genuine temporary entrant criterion.
The applicant’s immigration history
The applicant first arrived in Australia on 8 June 2012 on a 570 Student visa to study a Certificate III in ESL (Further Study) through Southern Cross Education Institute. The applicant commenced the course on 18 June 2012 and completed the course on 3 December 2012 (AAT Folio 51) according to the “Confirmation of Completion” letter from the education provider. Between February 2013 and 21 March 2014 the applicant completed three further English courses through Performance English (AAT Folios 56-58).
The applicant said to the Tribunal the reason for the significant gap in his studies between April 2014 and March 2018 was that “I was Dependant on my Wife’s student visa for this period, support her during her studies.” The applicant stated at hearing that he did not study during this time as he did not believe that he could have studied for a Bachelor degree while his wife was completing her Master’s degree.
The applicant informed the Tribunal that on 11 October 2011 he applied for a student visa and that this visa application was refused on 2 November 2011 due to financial capacity. The applicant told the Tribunal that he applied for another student visa on 13 December 2011 and for a second time his visa application was refused on 31 January 2012 “due to my financial sponsor did not want to provide more personal information”. The applicant stated at hearing that his financial sponsor, a friend, chose not to declare his financials to the officials.
The applicant informed the Tribunal that he departed Australia on three occasions to visit his family back in Colombia. During these three trips the applicant spent periods of time as a tourist in Argentina and the United States of America. The applicant informed the Tribunal that he travelled to Vietnam, Thailand, Malaysia and Singapore with his wife in November 2016 and to Bali, Indonesia in December 2017 for his birthday. The Tribunal considers the applicant’s travel movements neutral.
The Tribunal does not make an adverse finding against the applicant in terms of Clause 14(a) of Ministerial Direction 69, as there was no evidence before the Tribunal that the applicant had made previous applications for Australia or other countries. In relation to Clause 14(b)(i), (ii), (iii) and (iv) of Ministerial Direction 69, the Tribunal does not make any adverse findings against the applicant.
The applicant’s circumstances in their home country
The applicant informed the Tribunal that he had not completed his studies back in Colombia because “Unfortunately, we do not have a Bachelor in Business instructed in English with a major in marketing and communication in Colombia”. The Tribunal notes the applicant provided no evidence in support of his statement. The applicant further stated the reason for choosing his education provider was “Among many other Universities I choose CQU because it has a great reputation in the sector, and doing me the research I found that our Bachelor of Business with a major in Marketing is people-orientated and CQU reflects this, not just in the program itself, CQU’s atmosphere is surrounded by professional people with a lot of experience in the real market that always is focusing on the career of the students and their interests”. The Tribunal considers that a Bachelor of Business with a major in Marketing, or a similar course, is available in the home country or region of the applicant. The Tribunal finds the applicant does not have reasonable reasons for not undertaking a Bachelor of Business with a major in Marketing in his home country or region.
The applicant informed the Tribunal that his personal ties back in his home country of Colombia are his parents and that his sister, wife and girlfriend live in Australia. The applicant told the Tribunal that he maintains contact with his parents back in Colombia on a daily basis through the social media application WhatsApp and that he calls them on the telephone four times per week. In these circumstances, the Tribunal does not consider that the applicant’s personal ties overseas would serve as a significant incentive to return to his home country and for the applicant to cease residence in Australia.
The applicant stated at hearing that before coming to Australia he had completed High School in November 1998 and a Professional Technical Program in Graphic Design and Communication between July 2000 and August 2002. The applicant worked as a Customer Service Representative between June 2006 and May 2012 and was paid an annual salary of AUD7,636. The applicant informed the Tribunal that he currently lives in East Oakleigh with his girlfriend and that his contribution to the rent is AUD650 per month. The applicant informed the Tribunal that he has made a regular income since arriving in Australia. Between June 2012 and June 2016 he worked as a Marketing Officer part-time for Will World Education and was paid an annual salary of AUD14,400. Since June 2016 the applicant informed the Tribunal that he has worked for PAX Institute of Education in the area of Marketing and Communication and is paid an annual salary of AUD45,000. At hearing the Tribunal requested the applicant submit his “Notice of Assessment” from the Australian Taxation Office for the years ending 2014 through to 2018. The year ending 2014 stated that the applicant’s taxable income was AUD42,984 (AAT Folio 69); the year ending 2015 stated that the applicant’s taxable income was AUD52,647 (AAT Folio 67); the year ending 2016 stated that the applicant’s taxable income was AUD48,040 (AAT Folio 65); the year ending 2017 stated that the applicant’s taxable income was AUD40,202 (AAT Folio 64); and the year ending 2018 stated that the applicant’s taxable income was AUD36,690 (AAT Folio 63). The applicant further informed the Tribunal that he owns an apartment back in Colombia and that the value of this apartment is AUD78,000. Considering the applicant’s salary before coming to Australia was AUD7,636, since arriving in Australia the applicant has earnt a significantly higher salary as indicated in the Notices of Assessment from the Australian Taxation Office for the years ending 2014 through to 2018. For these reasons the Tribunal finds that the economic circumstances within Australia for the applicant would present a strong incentive for the applicant not to return to his home country.
The applicant informed the Tribunal that he has no concerns or requirements regarding military service commitments or political or civil unrest in his home country of Colombia. The Tribunal accepts the applicant’s evidence that he does not have any military service commitments in his home country and he is not aware of any political or civil unrest in his home country.
The Tribunal does not make an adverse finding against the applicant in terms of Clause 10 of Ministerial Direction 69, as there was limited evidence before the Tribunal in regards to the applicant’s circumstances in his home country relative to the circumstances of others in that country.
The applicant’s potential circumstances in Australia
The applicant informed the Tribunal that he does have significant ties within Australia, most notably his wife, sister and his new girlfriend. The Tribunal considers that the applicant does have significant ties within Australia and that this would present a strong incentive to remain in Australia.
At hearing the applicant informed the Tribunal that he is currently completing a Bachelor of Business through Central Queensland University which commenced on 5 March 2018 and is due to be completed by 1 November 2020 at a cost of AUD78,663. The applicant stated that he does not receive any financial support for his living expenses in Australia. Given that the applicant has been working in the area of marketing and communication in the education sector since arriving in 2012 the Tribunal considers that the applicant has gained the relevant work experience to pursue his future career plans back in his home country of Colombia. The applicant has had a significant period of time in which to pursue qualifications in marketing while working for both Will World Education and PAX Institute of Education during the seven years he has been living in Australia. For these reasons, the Tribunal is concerned that he is using the student visa programme to circumvent the intentions of the migration programme and to maintain ongoing residence in Australia.
The Tribunal has given regard to the applicant’s letter dated 26 September 2019 which mentioned:
I am writing this letter to support my student visa application to present the main reasons why I am applying for this visa; I came to Australia because I wanted to learn English, have the experience living abroad, and continue professionally preparing myself. Priorities were changing while the time was passing, my wife and I decided that she was going to be the first studying so I could support her emotionally and financially while I gained more working experience in the education industry as a marketing and communication officer.
After my wife finished her studies, I sticked to my initial plan that was to start my Higher education program and that was exactly what happened. With my work experience in marketing, I knew what exactly I wanted to study, a Bachelor of Business with major in Marketing at CQU University which I consider they have great teachers, good reputation with an excellent academic level.
Since I arrived in Melbourne; I was working in a student services' agency and later on I moved to an Educational Provider. Both jobs have taught me the necessary skills involved in the marketing environment and I have gained important work experience that will be totally worth it when I get back to my country.
Also, I will have a very interesting academic profile supported with my bachelor's degree that I am currently studying. Both work experience and Bachelor qualification are the perfect mix that important companies in Colombia are looking for.
Nowadays, everyone knows that a person who wants to succeed in this competitive world must have at least a bachelor's degree, or this is what happens in Colombia, someone without a bachelor as minimum qualification cannot move forward within a company or even have the opportunity to develop as a professional. And this is why I want to return to my home country with a competitive advantage of being graduated from an International and well recognized University, with a high level of English supported for a good working experience.
The applicant made no reference in his letter dated 26 September 2019 to the Tribunal that he had separated from his wife and that he had a new girlfriend. The way in which the applicant wrote this letter clearly indicated that he and his wife were still together and that the relationship had not broken down. For these reasons the Tribunal places little weight on the applicant’s letter dated 26 September 2019.
Post hearing the applicant submitted a further letter (AAT Folio 71) to the Tribunal dated 30 October 2019 and a letter from his current employer PAX Institute of Education dated 29 October 2019 (AAT Folio 70). The Tribunal has given regard to these submissions and places limited weight on the further letter from the applicant which covered the applicant’s future earning potential back in Colombia, his earnings during his time in Australia and that he considers himself a genuine student.
Value of the course to the applicant’s future
The Tribunal considers the course that the applicant is in the process of completing is not consistent with the other courses he has completed during his time in Australia. During his time in Australia the applicant has only completed two basic English courses between June 2012 and March 2014. The applicant stated at hearing that when he returns to his home country of Colombia at the completion of his current course he plans to find a job in the Marketing field. The applicant stated at hearing that he has no job offers. The applicant stated that “Upon my return to my home country, I expect to earn AUD20,000 (Annual ) according to the salaries and living cost of my country Colombia”. The applicant was not able to provide the Tribunal any further detail about his proposed future. The applicant was not able to provide any actual evidence of his future remuneration other than to say AUD20,000 will be a good salary, given his international qualifications. The applicant stated he will be paid well given that he has international qualifications. The Tribunal finds there is insufficient information before the Tribunal as to the remuneration the applicant could expect to receive in his home country or a third country compared with Australia using the qualifications to be gained from the proposed course of study. The applicant has already gained the relevant work experience to pursue his future career plans back in Colombia.
The Tribunal considers the applicant’s primary reason for remaining in Australia is for the purpose of work, that his future plans do not lie outside of Australia and that he is remaining enrolled in courses of study to meet the requirements of being granted further student visas so that he can maintain ongoing residence in Australia.
On the basis of the above, the Tribunal is not satisfied that the applicant intends genuinely to stay in Australia temporarily. Accordingly, the applicant does not meet cl.500.212(a).
Accordingly, the Tribunal is not satisfied that the applicant is a genuine applicant for entry and stay as a student as required by cl.500.212.
Given the above findings, the Tribunal finds that the criteria for the grant of a Subclass 500 (Student) visa are not met. The applicant does not claim to meet the criteria for a Subclass 590 (Student Guardian) visa. Accordingly, the decision under review must be affirmed.
Any other relevant matters
The applicant informed the Tribunal that he separated from his wife in May 2018. At hearing the applicant was supported by his new girlfriend.
The Tribunal does not make an adverse finding against the applicant in terms of Clause 15 of Ministerial Direction 69, as there was limited evidence before the Tribunal of any other relevant information provided by the applicant (or information otherwise available to the decision maker) when assessing the applicant’s intention to temporarily stay in Australia.
SECONDARY APPLICANT
As the primary applicant does not meet the criteria for the grant of the visa, the Tribunal must also affirm the decision to refuse the visa for the second named applicant, Ms Nancy Lorena Sanchez Galindo, as she does not satisfy cl.500.311.
DECISION
The Tribunal affirms the decision not to grant the applicants Student (Temporary) (Class TU) visas.
M. Edgoose
Member

Attachment – Direction No.69
DIRECTION NUMBER 69 – ASSESSING THE GENUINE TEMPORARY ENTRANT CRITERION FOR STUDENT VISA AND STUDENT GUARDIAN VISA APPLICATIONS
(Section 499)
I, PETER DUTTON, Minister for Immigration and Border Protection give this Direction under section 499 of the Migration Act 1958 (the Act).
Dated: 18 April 2016
Peter Dutton

Minister for Immigration and Border Protection
Note: Section 499(1) of the Act empowers the Minister to give a written direction to a person or body having functions or powers under the Act if the directions are about the performance of those functions; or the exercise of those powers. Under section 499(2) of the Act, the direction must not be inconsistent with the Act or the Migration Regulations 1994. Under section 499(2A) of the Act, the person or body must comply with the Direction.
Part 1 of Direction No. 69 - Preliminary
Name of Direction
This Direction is Direction No. 69 - Assessing the genuine temporary entrant criterion for Student visa and Student Guardian visa applications.
It may be cited as Direction No. 69.
Commencement
This Direction commences on 1 July 2016.
Interpretation
Act means the Migration Act 1958.
Genuine temporary entrant means a person who satisfies the genuine temporary entrant criterion for Student visa or Student Guardian visa applications.
Genuine temporary entrant criterion refers to clause 500.212(a), 500.312(a) and 590.215(a) at Schedule 2 to the Regulations.
Home country has the same meaning as the definition of that term in regulation 1.03 in Part 1 of the Regulations.
Regulations mean the Migration Regulations 1994.
Relative has the same meaning as the definition of that term in regulation 1.03 in Part 1 of the Regulations.
Spouse has the same meaning as the definition of the term in section 5F of the Act.
Student visa means a Subclass 500 (Student) visa
Student Guardian visa means a Subclass 590 (Student Guardian) visa.
Application
This Direction applies to delegates performing functions or exercising powers under section 65 of the Act in relation to assessing an applicant’s temporary entrant criterion for Student visa applications in Schedule 2 to the Regulations.
This Direction also applies to members of the Administrative Appeals Tribunal who review the decisions of primary decision-makers in relation to a Student visa or a Student Guardian visa application.
The genuine temporary entrant criterion must be satisfied by all applicants who make an application for either a Student visa seeking to satisfy the primary criteria for a Student Guardian visa.
Preamble
The Australian Government operates a student visa programme that enables people who are not Australian citizens or Australian permanent residents to undertake study in Australia. A person who wants to undertake a course of study under the student visa programme must obtain a student visa before they can commence a course of study in Australia. A successful applicant must be both a genuine temporary entrant and a genuine student.
An applicant who is a genuine temporary entrant will have circumstances that support a genuine intention to temporarily enter and remain in Australia, notwithstanding the potential for this intention to change over time to an intention to utilise lawful means to remain in Australia for an extended period of time or permanently.
The genuine temporary entrant criterion for Student visa applications requires the Minister to be satisfied that the applicant intends genuinely to stay in Australia temporarily, having regard to:
a.the applicant’s circumstances; and
b.the applicant’s immigration history; and
c.if the applicant is a minor — the intentions of a parent, legal guardian or spouse of the applicant; and
d.any other relevant matter.
This Direction provides guidance to decision makers on what factors require consideration when assessing the above paragraphs a to d, to determine whether the applicant genuinely intends to stay in Australia temporarily.
Decision makers must take a reasonable and balanced approach between the need to make a timely decision on a Student visa or Student Guardian visa application and the need to identify those applicants who, at time of decision, do not genuinely intend to stay in Australia temporarily
Part 2 of Direction No. 69 - Directions
Assessing the genuine temporary entrant criterion
1.Decision makers should not use the factors specified in this Direction as a checklist. The listed factors are intended only to guide decision makers when considering the applicant’s circumstances as a whole, in reaching a finding about whether the applicant satisfies the genuine temporary entrant criterion.
2.Decision makers should assess whether, on balance, the genuine temporary entrant criterion is satisfied, by:
a.considering the applicant against all factors specified in this Direction; and
b.considering any other relevant information provided by the applicant (or information otherwise available to the decision maker).
3.Decision makers may request additional information and/or further evidence from the applicant to demonstrate that they are a genuine temporary entrant, where closer scrutiny of the applicant's circumstances is considered appropriate.
4.Circumstances where further scrutiny may be appropriate include but are not limited to:
a.information in statistical, intelligence and analysis reports on migration fraud and immigration compliance compiled by the department indicates the need for further scrutiny;
b.the applicant or a relative of the applicant has an immigration history of reasonable concern;
c.the applicant intends to study in a field unrelated to their previous studies or employment; and
d.apparent inconsistencies in information provided by the applicant in their Student visa application.
5.An application for a Student visa or a Student Guardian visa should be refused if, after weighing up the applicant’s circumstances, immigration history and any other relevant matter, the decision maker is not satisfied that the applicant genuinely intends a temporary stay in Australia.
The applicant’s circumstances
6.Decision makers should have regard to the applicant’s circumstances in their home country and the applicant’s potential circumstances in Australia.
7.For primary applicants of Subclass 500 Student visas, decision makers should have regard to the value of the course to the applicant’s future.
8.Weight should be placed on an applicant’s circumstances that indicate that the Student visa or Student Guardian visa is intended primarily for maintaining residence in Australia.
The applicant’s circumstances in their home country
9.When considering the applicant’s circumstances in their home country, decision makers should have regard to the following factors:
a.whether the applicant has reasonable reasons for not undertaking the study in their home country or region if a similar course is already available there. Decision makers should allow for any reasonable motives established by the applicant;
b.the extent of the applicant’s personal ties to their home country (for example family, community and employment) and whether those circumstances would serve as a significant incentive to return to their home country;
c.economic circumstances of the applicant that would present as a significant incentive for the applicant not to return to their home country. These circumstances may include consideration of the applicant’s circumstances relative to the home country and to Australia;
d.military service commitments that would present as a significant incentive for the applicant not to return to their home country; and
e.political and civil unrest in the applicant’s home country. This includes situations of a nature that may induce the applicant to apply for a Student visa or Student Guardian visa as means of obtaining entry to Australia for the purpose of remaining indefinitely. Decision makers should be aware of the changing circumstances in the applicant’s home country and the influence these may have on an applicant’s motivations for applying for a Student visa or a Student Guardian visa.
10.Decision makers may have regard to the applicant’s circumstances in their home country relative to the circumstances of others in that country.
The applicant’s potential circumstances in Australia
11.In considering the applicant’s potential circumstances in Australia, decision makers should have regard to the following factors:
a.The applicant’s ties with Australia which would present as a strong incentive to remain in Australia. This may include family and community ties;
b.evidence that the student visa programme is being used to circumvent the intentions of the migration programme;
c.whether the Student visa or Student Guardian visa is being used to maintain ongoing residence;
dwhether the primary and secondary applicant(s) have entered into a relationship of concern for a successful Student visa outcome. Where a decision maker determines that an applicant and dependant have contrived their relationship for a successful Student visa outcomes, the decision maker may find that both applicants do not satisfy the genuine temporary entrant criterion; and
e.the applicant’s knowledge of living in Australia and their intended course of study and the associated education provider; including previous study and qualifications, what is a realistic level of knowledge an applicant is expected to know and the level of research the applicant has undertaken into their proposed course of study and living arrangements.
Value of the course to the applicant’s future
12.Decision makers should have regard to the following factors when considering the value of the course to the applicant’s future:
a.whether the student is seeking to undertake a course that is consistent with their current level of education and whether the course will assist the applicant to obtain employment or improve employment prospects in their home country. Decision makers should allow for reasonable changes to career or study pathways; and
b.relevance of the course to the student’s past or proposed future employment either in their home country or a third country; and
c.remuneration the applicant could expect to receive in the home country or a third country, compared with Australia, using the qualifications to be gained from the proposed course of study.
The applicant's immigration history
13.An applicant’s immigration history refers both to their visa and travel history.
14.When considering the applicant’s immigration history, decision makers should have regard to the following factors:
a.Previous visa applications for Australia or other countries, including:
i.if the applicant previously applied for an Australian temporary or permanent visa, whether those visa applications are yet to be finally determined (within the meaning of subsection 5(9) of the Act), were granted, or grounds on which the application(s) were refused; and
ii.if the applicant has previously applied for visa(s) to other countries, whether the applicant was refused a visa and the circumstances that led to visa refusal.
b.Previous travels to Australia or other countries, including:
i.if the applicant previously travelled to Australia, whether they complied with the conditions of their visa and left before their visa ceased, and if not, were there circumstances beyond their control;
ii.whether the applicant previously held a visa that was cancelled or considered for cancellation, and the associated circumstances;
iii.the amount of time the applicant has spent in Australia and whether the Student visa or Student Guardian visa may be used primarily for maintaining ongoing residence, including whether the applicant has undertaken a series of short, inexpensive courses, or has been onshore for some time without successfully completing a qualification; and
iv.if the applicant has travelled to countries other than Australia, whether they complied with the migration laws of that country and the circumstances around any non-compliance
If the applicant is a minor— the intentions of a parent, legal guardian or spouse of the applicant
15.If the primary or secondary applicant for a Subclass 500 Student visa is a minor, decision makers should have regard to the intentions of a parent, legal guardian or spouse of the applicant.
Any other relevant matters
16.Decision makers should also have regard to any other relevant information provided by the applicant (or information otherwise available to the decision maker) when assessing the applicant’s intention to temporarily stay in Australia. This includes information that may be either beneficial or unfavourable to the applicant.

[2019] AATA 4934

13 November 2019

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Procedural Fairness

Statutory Construction