Sharma and Minister for Immigration and Border Protection
[2016] AATA 537
•27 July 2016
Sharma and Minister for Immigration and Border Protection (Migration) [2016] AATA 537 (27 July 2016)
Division
GENERAL DIVISION
File Number(s)
2016/2500
Re
Adarshveer Sharma
APPLICANT
And
Minister for Immigration and Border Protection
RESPONDENT
DECISION
Tribunal Egon Fice, Senior Member
Date 27 July 2016 Place Melbourne The Tribunal affirms the decision to reject the application for a Student (Temporary) (Class TU) visa.
....................................[sgd]....................................
Egon Fice, Senior Member
Catchwords
IMMIGRATION AND BORDER PROTECTION – application for Student (Temporary) (Class TU) dependant visa refused – failure to satisfy character test – applicant found guilty of a sexually based offence involving a child – indecent act in presence child under 16 – applicant discharged without conviction – where sexual crime committed against a vulnerable member of the community – where serious risk to Australian community if applicant re-offended – where Australian community would expect application to be refused – decision affirmed.
Legislation
Migration Act 1958 (Cth) s 501
Sentencing Act 1991 (Vic) s 8Sex Offender Registration Act 2004 (Vic)
Secondary Materials
Ministerial Declaration no 65 – Visa refusal and cancellation under s 501 and revocation of a mandatory cancellation of a visa under s 501CA (Scott Morrison MP, Minister for Immigration and Border Protection)
REASONS FOR DECISION
Egon Fice, Senior Member
Mr Adarshveer Sharma first arrived in Australia on 19 April 2013 as the holder of a Student (Temporary) (Class TU) visa. An application for a Student (Temporary) visa was made by his wife, Manpreet Kaur. Mr Sharma was included on the application as her spouse. On 11 April 2014 Mr Sharma lodged a further application for a Student (Temporary) (Class TU) visa based on his spousal relationship with the primary visa applicant, Ms Kaur, and, pending grant of that visa, he was given a Bridging A (Class WA) Visa.
On 8 July 2015 an officer with the Visa Applicant Character Consideration Unit of the Department of Immigration and Border Protection wrote to Mr Sharma giving him notice that the Department considered refusing his visa application. The reason for that consideration was that the Department held information about his criminal history which suggested he may not pass the character test, in particular the test set out in
s. 501(6)(b)(ii) of the Migration Act 1958 (the Act).
The basis for the Department’s consideration was a Community Correction Order made by the Frankston Magistrates’ Court on 15 July 2014 which found, without conviction, the charge of Indecent Act in Presence Child Under 16 proved against Mr Sharma. A registered migration consultant responded to that letter on behalf Mr Sharma on 5 August 2015.
In a letter dated 5 May 2016 a delegate of the Minister informed Mr Sharma that his application for a visa was refused. The delegate also advised Mr Sharma that any other visa that he may hold, other than a Protection Visa, was now taken to be cancelled by the operation of law. In other words, Mr Sharma’s bridging visa had also been cancelled. Mr Sharma was then taken into immigration detention.
THE OFFENCES
On 12 August 2013 Mr Sharma was arrested and charged with the offence of committing an indecent act in the presence of a child under the age of 16 years to whom he was not married. The indecent act in question was of masturbation. The incident occurred on 12 August 2013. Briefly, the girl was on her way to school when a car came past her and stopped about five or 6 m in front of her. The man inside the car was holding a Samsung S Galaxy phone, which was white in colour. He asked for directions to a particular address. She said the male was in his early 20s around 24, 25 years of age. She described his clothing.
The girl stated that on approaching the car, she realised that the male had exposed his penis was rubbing it sexually. She described herself shocked and scared but couldn’t scream. She said she simply turned around and started running. On arriving at school and seeing the librarian, she explained what had happened. She was taken to the sick bay room crying. The girl received counselling. She described the colour of the car as being really, really dark green. It was a sedan which she described as appearing somewhat old. She described the man as being of Indian origin because of the way he spoke. She said she had an Indian friend and was familiar with the accent.
Mr Sharma was arrested on the day this incident took place. The clothing he was then wearing corresponded with the description given by the girl. Several days after the initial interview, on 15 August 2013, the police showed the girl a photo board which included, amongst others, a photograph of Mr Sharma. She correctly identified Mr Sharma from those photographs.
The LEAP Victoria Police extract also records two sub-incident offences which the police intended to proceed with by summons. The first incident occurred on 19 July 2013 and it involved a schoolgirl aged 14 years. This incident was described as stalking.
The victim said she was on her way to school and when about to cross a road, a man in a car pulled down the window and asked her if she wanted a ride. She declined, put on her headphones, and walked off. She claimed the driver of the vehicle continued to watch her as she crossed a park adjoining the street in order to avoid the vehicle. The vehicle slowly drove around the street towards her direction and appeared to be attempting to intercept her movement.
The victim described herself as being scared that the driver may exit the vehicle and harm her, as his driving demeanour was abnormal to her. The description of the driver fairly accurately described Mr Sharma. Significantly, the schoolgirl obtained the registration number of the motor vehicle and its description and it matched the vehicle owned by Mr Sharma.
The second sub-incident occurred on 10 August 2013. It involved a 14-year-old schoolgirl. In the transcript of interview of the victim by the police, the girl described that she was walking to school and there was a car parked on the side of the road with the man sitting in it. He had his mobile phone out of the window and asked her if she could show him and address. She said the mobile phone was white, large, and it may have been a Samsung or HTC phone. She walked up to the car and noted that the occupant had his pants down and his private parts were exposed.
The victim later explained that the exposed part was the man’s penis. She also described him as touching it and fiddling with it or something. The description she gave to the police of the person in the car fits Mr Sharma. The victim said that she thought he was Indian because of his skin tone and face. She described him as being around 20 or 30 years of age. According to the girl, the man also asked her to get into the car but she ignored him and walked on to her school. She said he reversed the car along the road at the same pace she was walking at. She was uncertain of the colour of the car, describing it as dark green and she could not remember the registration number. She thought it may have been a Toyota Camry, although she described it as being an older car.
I also had in evidence a statement made by a police officer who said on Monday, 12 August 2013, he was performing divisional van duties with another constable. While on duty, he received a job from Police Communications to attend an address in relation to an Indian male flashing himself at a female passer-by. He recalled that he had previously received a similar job while working in the watch-house. On referring to his notes, he found the registration of the vehicle given in that previous job.
The divisional van drove past the address where the vehicle was registered and noticed the vehicle was not there. The police then attended the school and spoke with the Deputy Principal. Following that interview, the police went back to the address at which the vehicle was registered and noticed the vehicle had returned to the address. The description and registration number matched what the police officer had previously noted. The officer said he was asked to remain and observe the vehicle and to intercept the driver.
Later that morning, the officer observed an Indian male leave the address and walk towards the school. He was approximately 25 – 30 years old and of Indian origin. He noted the type and colour of clothing that the man was wearing and it matched the description given by the schoolgirl. The police then arrested this person, who was identified as Mr Sharma, and conveyed him to the Keilor Downs police station.
The police also took a statement from the owner of the unit where Mr Sharma and his wife were residing. The owner described Mr Sharma as having gone out about three or four times during the morning of 12 August 2013.
A Detective Senior Constable who was then with the Footscray Sexual Offences and Child Abuse Investigation Team interviewed Mr Sharma on 12 August 2013. The Detective Senior Constable observed the clothing which Mr Sharma was wearing. He described that clothing, including its colour, which is identical to the clothes the girl observed on that day. On being asked if he had a mobile phone, Mr Sharma produced a white Samsung Galaxy mobile phone.
The Detective Senior Constable also said he compiled a photo board containing a photograph of the suspect, Mr Sharma, and matched him with 11 other similar photographs. Mr Sharma’s image was placed in position number 8. That is the photograph which the schoolgirl said most closely matched the description of the male who exposed himself to her. I had in evidence a copy of that photo board and photograph number 8 is plainly a photograph of Mr Sharma.
I have taken some care in setting out the above evidence for the reason that in his evidence on hearing this matter, Mr Sharma denied that he committed any of the offences with which he was charged. That is despite the fact that, although denying that he was the offender when questioned by the police, he subsequently pleaded guilty.
Furthermore, on 4 September 2014 Mr Sharma made a Statutory Declaration referring to the incident of 12 August 2013 in which he admitted commission of that offence. He said:
I don’t know how I have done that mistake. I was feeling really sorry about the girl. During my case I had gone through a Psychiatric Test. Dr Pamela Matthews mentioned in her report that it was not a mental illness, this incident was happened due to a lot of stress or tensions.
I had in evidence a report from Dr Matthews to which I will refer presently.
Mr Sharma made a further Statutory Declaration 3 August 2015. It was a response to the Notice of Intention to refuse his visa application. Mr Sharma declared:
I acknowledge I have committed this offence of a serious nature but I never had any criminal record in the past before that. At that time I was in stress and depression because I was quite new in Australia and didn’t have any job that time.
The evidence Mr Sharma gave before me was taken under oath. I warned him about the possibility of self-incrimination if he chose to answer questions from Mr L Brown of counsel, who appeared on behalf of the Minister, but Mr Sharma nevertheless proceeded to state that he had not committed the offences I have outlined above. I also told Mr Sharma that I could not go behind the judgement made by the Magistrate on 15 July 2014 which was based on an admission of guilt.
The LEAP – Victoria Police Court Outcomes Report which was in evidence indicates that on 15 July 2014 at the Frankston Magistrates Court, Mr Sharma was sentenced to a Community Correction Order for 18 months without conviction. Having been sentenced to a registrable offence under the Sex Offender Registration Act 2004 (Vic), he was placed on the sex offender’s register and required to report to Victoria Police for a period of 8 years.
VISA REFUSAL
Section 501(1) of the Act provides:
(1) The Minister may refuse to grant a visa to a person if the person does not satisfy the Minister that the person passes the character test.
Note: Character test is defined by subsection (6).
Relevantly, s. 501(6) of the Act also provides:
For the purposes of this section, a person does not pass the character test if:
(a)…
(e)a court in Australia or a foreign country has:
(i) convicted the person of one or more sexually based offences involving a child; or
(ii) found the person guilty of such an offence or found a charge against the person proved for such an offence, even if the person was discharged without conviction; or…
Plainly, because Mr Sharma has been found guilty of a sexually based offence involving a child, despite no conviction being recorded, he does not pass the character test. Accordingly, the discretion provided for in s. 501(1) is enlivened. In other words, the Minister (or his delegate) may determine whether or not the visa should be granted.
In arriving at the discretionary decision, the decision maker, including this Tribunal which, on an application for review, stands in the decision maker’s shoes, must have regard to
s. 499 of the Act. Relevantly, it provides:
(1) The Minister may give written directions to a person or body having functions or powers under this Back if the directions are about:
(a)the performance of those functions; or
(b)the exercise of those powers.
…
(2A) A person or body must comply with the direction under subsection (1).
The current direction made by the Minister pursuant to the Act is Direction No. 65 (the Ministerial Direction). Among the principles set out in the Ministerial Direction are these, which are relevant:
6.3 Principles
(1) Australia has a sovereign right to determine whether non-citizens who are of character concern are allowed to enter and/or remain in Australia. Being able to come to or remain in Australia is a privilege Australia confers on non-citizens in the expectation that they are, and have been, law-abiding, will respect important institutions, such as Australia’s law enforcement framework, and will not cause or threaten harm to individuals or the Australian community.
…
(3) A non-citizen who has committed a serious crime, including of a violent or sexual nature, and particularly against vulnerable members of the community such as minors, the elderly or disabled, should generally expect to be denied the privilege of coming to, or to forfeit the privilege of staying in, Australia.
(4) In some circumstances, criminal offending or other conduct, and the harm that would be caused if it were to be repeated, may be so serious, that any risk of similar conduct in the future is unacceptable. In these circumstances, even other strong countervailing considerations may be insufficient to justify not cancelling or refusing the visa.
(5) Australia has a low tolerance of any criminal or other serious conduct by people who have been participating in, and contributing to, the Australian community only for a short period of time. However Australia may afford a higher level of tolerance of criminal or other serious conduct in relation to a non-citizen who has lived in the Australian community for most of their life, or from a very young age.
(6) Australia has a low tolerance of any criminal or other serious conduct by visa applicants or those holding a limited stay visa, reflecting that there should be no expectation that such people should be allowed to come to, or remain permanently in, Australia.
The Ministerial Direction says this about taking the relevant considerations into account:
(1) Decision-makers must take into account the primary and other considerations relevant to the individual case. There are differing considerations depending on whether a delegate is considering whether to refuse to grant a visa to a visa applicant, cancel the visa of a visa holder, or revoke the mandatory cancellation of a visa. These different considerations are articulated in Parts A, B and C. Separating the considerations for visa holders and visa applicants recognises that non-citizens holding a substantive Visa will generally have an expectation that they would be permitted to remain in Australia for the duration of that visa, whereas a visa applicant should have no expectation that a visa application will be approved.
…
(4) Primary consideration should generally be given greater weight than other considerations.
(5) One or more primary considerations may outweigh other primary considerations.
PRIMARY CONSIDERATIONS
Part B applies to visa applicants. In deciding whether to refuse a non-citizen’s visa, the primary considerations are:
(a)protection of the Australian community from criminal or other serious conduct;
(b)the best interests of minor children in Australia; and
(c)expectations of the Australian community.
Protection of the Australian community
The Ministerial Direction states there is a low tolerance for visa applicants who have previously engaged in criminal or other serious conduct. Decision-makers are required to also give consideration to the nature and seriousness of the non-citizen’s conduct to date and the risk to the Australian community should the non-citizen commit further offences engage in other serious conduct.
The nature and seriousness of the conduct
In considering this heading, I must have regard to:
(a)the principle that, without limiting the range of offences that may be considered a serious, sexual crimes are viewed seriously;
(b)the principle that crimes committed against vulnerable members of the community such as minors are serious;
(c)the sentence imposed by the court for a crime or crimes; and
(d)the frequency of the non-citizen’s offending and whether there is any trend of increasing seriousness.
It was submitted on behalf of Mr Sharma that while his offending was serious, it was at the low end of the range of seriousness. That was because no conviction was recorded and no custodial sentence given. With respect, I cannot accept this submission. Sexually related offences and offences against the most vulnerable, which include children, are viewed most seriously, particularly when considering visa applications or cancellations.
Furthermore, it appears that the Magistrates’ Court dealt only with two of the three incidents, being those which occurred on 10 and 12 August 2013. There is no indication that it took into account the further incident regarding stalking, which the police intended to pursue on summons.
The reason why I am seriously concerned with Mr Sharma’s conduct is that this is not confined to a single incident but three incidents. The first incident which occurred on 19 July 2013 appears to have been a precursor to the two subsequent incidents. As I have described above, a young girl going to school believed that a person, fitting the description of Mr Sharma, driving a motor vehicle which fits the description of Mr Sharma’s car including its registration number, was stalking her. She became sufficiently frightened to report that to the police and Mr Sharma was interviewed in respect of that incident.
The excuse given for Mr Sharma’s conduct was that he was working in or about the vicinity of the school. However, despite being interviewed by the police, what appears to be an escalation of his offending occurred on 10 and 12 August 2013.
In the second incident, Mr Sharma, according to the victim, attempted to get her into the car by suggesting he needed help. The possibility of this incident escalating is plainly apparent. The evidence given of the third incident indicates that Mr Sharma had quite specifically targeted his victim, turning onto the road along which she was walking and parking a short distance in front of her. The description given by other witnesses at the school when she arrived there clearly expresses the fear and trauma suffered by that girl. It was not some minor incident.
As for not recording a conviction, the grounds for arriving at such a decision are set out in s. 8 of the Sentencing Act 1991 (Vic). Relevantly, that Act provides:
(1) In exercising its discretion whether or not to record a conviction, a court must have regard to all the circumstances of the case including –
(a)the nature of the offence; and
(b)the character and past history of the offender; and
(c)the impact of the recording of a conviction on the offender’s economic or social well-being or on his or her employment prospects.
It should be apparent that the seriousness of the offence is but one factor which is taken into account in determining whether a conviction is recorded. In any event, the fact that his offence requires him to be registered as a sex offender and is required to report to Victoria Police for eight years indicates that this matter is not trivial. I find Mr Sharma’s criminal conduct to be very serious.
Risk to the Australian community
Given the nature of Mr Sharma’s offending, in particular that he was questioned by the Police regarding the first incident on 19 July 2013 which clearly escalated into the conduct described in the next two incidents, there clearly remains a risk that Mr Sharma will reoffend.
Although Ms Matthews, a forensic psychologist, came to the conclusion that Mr Sharma’s risk of future offending in a similar manner was estimated to be low, I note that no mention is made in her report of the incident which occurred on 19 July 2013 or the incident on 10 August 2013. Ms Matthews’ opinion seems to be based on a single incident.
Furthermore, Ms Matthews described the conduct as exhibitionist in quality only and that his behaviour appeared to be a dysfunctional coping response to a variety of psychosocial stressors coalescing all at once. With respect to Ms Matthews, it is not clear that she was provided with the transcript of the interviews of any victims of Mr Sharma’s offending.
Ms Matthews described having a copy of charge sheets which record two charges, being the incidents of 10 and 12 August 2013. No reference is made to the stalking incident, probably because a summons was not authorised for that incident. Nevertheless, in my opinion, it discloses a course of conduct which escalated from stalking to the indecent acts which occurred subsequently. Also disturbing is the transcript of interview with the victim of the second incident which indicates that the girl was being enticed to get into the car with Mr Sharma.
Considering the evidence in its entirety, I find that the risk to the Australian community should Mr Sharma remain in Australia is real and not necessarily low as found by Ms Matthews. That is because it is apparent that Ms Matthews did not have all relevant information before her in making her assessment.
Best interests of minor children
Mr Sharma and his wife do not have any children. This consideration is not relevant in
Mr Sharma’s case.Expectations of the Australian community
Under this consideration, the Ministerial Direction relevantly states:
(1) The Australian community expects non-citizens to obey Australian laws while in Australia. Where a non-citizen has breached, or where there is an unacceptable risk that they will breach this trust or where the non-citizen has been convicted of offences in Australia or elsewhere, it may be appropriate to refuse the visa application of such a person. Visa refusal may be appropriate simply because the nature of the character concerns or offences are such that the Australian community would expect that the person should not be granted a visa. Decision-makers should have due regard to the Government’s views in this respect.
I have no doubt whatsoever that were the Australian community aware of the circumstances described above, they would expect that Mr Sharma would not be granted a visa. Sexual offences against children are regarded as particularly abhorrent. The traumatic effect on children, even at the level of offending described above, can be serious and long-lasting.
OTHER CONSIDERATIONS
Clause 12 of the Ministerial Direction sets out some other considerations which must be taken into account where relevant. It does not purport to be an exclusive list. There are two matters which I consider to be relevant, that is, impact on family members and impact on victims.
Impact on family members
Mr Sharma has a wife, and they have been married since July 2013. While it seems obvious that refusal to grant Mr Sharma a visa in his capacity as the spouse of Ms Kaur, who is the primary visa holder, will have some effect on their relationship, there was no evidence that it would impact in any way on Ms Kaur’s visa or right to remain in Australia to complete her studies. Curiously, I did not have in evidence a statement from Ms Kaur supporting Mr Sharma’s application for review before the Tribunal. It was not planned that she give oral evidence, although it was explained that she was unwell and could not attend the hearing.
I did have in evidence a transcript of a telephone conversation between Ms Kaur and the barrister who had acted for Mr Sharma in the Magistrate Court proceeding. It appears from that discussion that the barrister was of the view that by pleading guilty, Mr Sharma would not have an issue with his visa. I have reduced that to the singular, although the transcript indicates that Ms Kaur was concerned about our visas. Ms Kaur also appeared to be of the opinion that her visa would also be cancelled. It also appears that Ms Kaur was of the belief, possibly instilled by Mr Sharma, that the incidents described above did not occur or that Mr Sharma was not involved.
Ms Kaur clearly has a misunderstanding of both issues. First, there was no visa cancellation but simply a refusal to issue Mr Sharma with a further Student Visa. Secondly, simply because no conviction was recorded by the Magistrate does not mean that the incidents of sexual impropriety did not occur. The objective evidence on that is very strong.
Given the lack of evidence from Ms Kaur, I am unable to make any findings regarding the impact of a refusal to grant Mr Sharma a further student visa would have on her. It is not my role to speculate.
Impact on victims
The only evidence I had before me regarding the impact on victims is from the transcripts of interviews conducted by the police. Those interviews were taken shortly after the events took place. I therefore can only describe the impact at that point in time and not in relation to present or any likely future consequences.
The victim of the first incident described that she was scared. She was particularly scared that Mr Sharma would have come out of the car and grabbed her. The victim of the second incident was plainly terrified and was crying when she got to her school. She was unable talk to anyone to begin with. She was extremely upset by the incident. The victim of the third incident said that she was disgusted. She was afraid to tell her mother.
The problem of course is that I have no idea whether or what affect these incidents will have on the victims in the future. Plainly, it was a frightening experience for all of the victims.
Significantly, Mr Sharma, in his statutory declaration made on 4 September 2014, makes no mention of concern for the victims or remorse. In fact, Ms Matthews in her statement said there was no evidence of minimisation or denial of his behaviour or the impact upon the victim.
CONCLUSIONS
Plainly, Mr Sharma does not pass the character test set out in s. 501(6) of the Act because the two charges against him were proved for the offences committed, even though he was discharged without conviction. In fact, he pleaded guilty to those offences.
I have found that the relevant primary considerations weigh heavily against the exercise of the discretion in s. 501 (1) of the Act in favour of granting Mr Sharma a visa. There can be no doubt that the Australian community would expect its children to be protected against the type of offending conducted by Mr Sharma. It cannot be seriously doubted that Australia has a low tolerance of criminal conduct against minors, particularly sexual offences. The offences should be viewed very seriously given that they were sexual crimes committed against children.
While I have taken into account the fact that no conviction was recorded against Mr Sharma, that does not result in a different conclusion. A number of considerations may be taken into account in determining whether or not to record a conviction and the seriousness of the offending is only one of many possible factors.
Although Ms Matthews, a forensic psychologist, regarded Mr Sharma’s risk of reoffending as extremely low, it appears her analysis was not based on all of the evidence which was available. For that reason, I have doubted the accuracy of her finding. Taking into account all of the evidence including the stalking incident, it is apparent that each event was premeditated and, to a certain extent planned.
The victims were particularly targeted because they were young schoolgirls walking alone. There was also evidence of escalation of that kind of activity from stalking to committing indecent acts in the presence of children. It is also apparent that Mr Sharma attempted to entice those children to participate in sexual acts. I find that any risk that Mr Sharma’s deviant sexual behaviour may be repeated would be unacceptable to the Australian community.
Although Ms Matthews found Mr Sharma to be remorseful and described him as presenting genuinely embarrassed and ashamed, I did not find him as a person fitting that description. In fact, in the course of his oral evidence, he repeatedly maintained he did not commit the sexual acts as described. That is despite being warned that he need not answer questions which might tend to incriminate him particularly as he had previously made two statutory declarations admitting guilt.
Mr Sharma insisted on putting into evidence the transcript of the telephone conversation his wife had with the barrister who clearly advised him regarding the matter that was before the Magistrates’ Court. This was done for the purpose of convincing me that the only reason he pleaded guilty was because he could not afford legal representation and that he was advised that in doing so, it would not have a detrimental effect on his visa. I found his evidence to be wholly unsatisfactory.
Regarding the other considerations, which generally must be given less weight than the primary considerations, the only relevant matters appear to be the impact on his wife and the impact on victims. While the transcript of the discussion Ms Kaur had with the barrister clearly express her concerns about her visa being cancelled, there was nothing before me to suggest that the Minister’s delegate had considered cancelling her visa. Furthermore, had she been seriously concerned for her husband, I would have expected her to have provided a written statement in support of granting him a visa. She did not do so. Nor was she present at the hearing of this application, I was told, for the reason that she was unwell. In any event, I find I cannot, in the absence of evidence from Ms Kaur, come to any conclusion about the impact on her of a refusal to grant her husband a visa.
The evidence I had before me allowed me to state, as I have done, the impact that the various incidents had on the victims. The problem with the type of offending which occurred is that its consequences not infrequently manifest at a much later time. I have expressed concerns about that but, in the absence of expert evidence, I can take that no further.
I find that the overwhelming weight of evidence in this case supports the decision taken by a delegate of the Minister on 3 May 2016 to refuse to grant to Mr Sharma a Student (Temporary) Visa. I affirm that decision.
67. I certify that the preceding 66 (sixty-six) paragraphs are a true copy of the reasons for the decision herein of Egon Fice, Senior Member
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Associate
Dated 27 July 2016
Date(s) of hearing
21 July 2016
Advocate for the Applicant
Dr Vijay Kumar Sharma
Counsel for the Respondent
Mr L Brown
Solicitors for the Respondent Sparke Helmore Lawyers
Key Legal Topics
Areas of Law
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Immigration
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Administrative Law
Legal Concepts
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Judicial Review
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Natural Justice
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Procedural Fairness
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Statutory Construction
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