Singh v Minister for Immigration
[2020] FCCA 2799
•15 October 2020
FEDERAL CIRCUIT COURT OF AUSTRALIA
| SINGH v MINISTER FOR IMMIGRATION & ANOR | [2020] FCCA 2799 |
| Catchwords: MIGRATION – Student (subclass 500) visa – decision of the Administrative Appeals Tribunal – where Tribunal asked to determine whether applicant is a genuine temporary entrant – no jurisdictional error – application dismissed. |
| Legislation: Migration Act 1958 (Cth), pt.5, div.5, ss.65, 359, 359A, 359AA, 360 Migration Regulations 1994 (Cth), cl.500.212 of sch.2 |
| Cases cited: Bala v Minister for Immigration & Border Protection [2019] FCA 600 Eros v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 1061 Minister for Immigration & Border Protection v Singh (2014) 231 FCR 437 Minister for Immigration & Ethnic Affairs v Wu Shan Liang (1996) 185 CLR 259 |
| Applicant: | VIKRAMJEET SINGH |
| First Respondent: | MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS |
| Second Respondent: | ADMINISTRATIVE APPEALS TRIBUNAL |
| File Number: | PEG 473 of 2019 |
| Judgment of: | Judge Kendall |
| Hearing date: | 12 October 2020 |
| Date of Last Submission: | 12 October 2020 |
| Delivered at: | Perth |
| Delivered on: | 15 October 2020 |
REPRESENTATION
| Applicant: | In person |
| Counsel for the First Respondent: | Ms A Ladhams |
| Second Respondent: | Submitting appearance, save as to costs |
| Solicitors for the Respondents: | Australian Government Solicitor |
ORDERS
The application be dismissed.
| FEDERAL CIRCUIT COURT OF AUSTRALIA AT PERTH |
PEG 473 of 2019
| VIKRAMJEET SINGH |
Applicant
And
| MINISTER FOR IMMIGRATION, CITIZENSHIP, MIGRANT SERVICES AND MULTICULTURAL AFFAIRS |
First Respondent
| ADMINISTRATIVE APPEALS TRIBUNAL |
Second Respondent
REASONS FOR JUDGMENT
Introduction
The applicant is a citizen of India. He arrived in Australia on
8 February 2014 on a student visa (Court Book (“CB”) 55). On
13 March 2017, the applicant applied for a Student (Temporary) (class TU) Student (subclass 500) visa (the “visa”) (CB 1-45). The applicant indicated that he intended to study hospitality and business courses.
On 19 July 2017, a delegate of the first respondent (the “Minister”) refused to grant the applicant the visa (CB 49-56). The delegate found that the applicant did not meet cl.500.212 of the Migration Regulations 1994 (the “Regulations”) as the applicant did not “genuinely intend to stay in Australia temporarily”.
The applicant sought review of the delegate’s decision on 2 August 2017 at the Administrative Appeals Tribunal (the “Tribunal”) (CB 57-58).
On 22 February 2019, the applicant was invited by the Tribunal pursuant to s.359 of the Migration Act 1958 (Cth) (the “Act”) to provide information about his current course of study and his “stay in Australia as a student” (CB 65-74).
On 21 March 2019, the applicant’s migration agent provided supporting documents and submissions in response to the Tribunal’s invitation to comment (CB 81-102).
The applicant attended a hearing before the Tribunal on 1 May 2019 (CB 116-118).
On 27 November 2019, the Tribunal affirmed the decision not to grant the applicant the visa (CB 123-133).
On 2 December 2019, the applicant filed an application for judicial review in this Court seeking a review of the Tribunal’s decision pursuant to s.476 of the Act. To obtain assistance, the applicant must satisfy the Court that the Tribunal has fallen into jurisdictional error.
Tribunal’s Decision
The Tribunal’s decision is 11 pages long and spans 33 paragraphs.
The Tribunal began by identifying the type of visa the applicant had applied for. The Tribunal noted that the delegate had refused the visa because the delegate was not satisfied that cl.500.212 had been met. The Tribunal also noted that it had sent a request pursuant to s.359 of the Act for further information and that the applicant had responded to that request for information (at [1]-[6]).
The Tribunal then outlined the relevant legal provisions and summarised Direction 69, as follows:
9. 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?
10. 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.
11. 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 Minister’s written submissions (at [19]-[22]) dated 7 August 2020 accurately summarise the balance of the Tribunal’s decision. The Court adopts those submissions as its own. With some alterations, that summary provides as follows.
The Tribunal summarised the applicant’s evidence in detail (at [12]-[22]). The Tribunal observed that:
a)the applicant had been working at McDonalds as a crew member since 2014 and had earned $20,000 per annum. He had also worked as a cook at the Coffee Club Café (at [13]);
b)the applicant’s younger brother was in Australia and the applicant shared accommodation with him. His parents are in India and he contacted them by telephone or video when he was able to do so (approximately three times a week) (at [14]);
c)since arriving in Australia in 2014, the applicant has travelled to India on two occasions. The applicant had close family friends who resided in Perth. While the applicant still had ties in India (as his parents lived there), the fact that his brother and close family friends were living in Perth might be a strong incentive for the applicant to remain in Australia (at [15]);
d)there were general statements made in the applicant’s submissions about the practical experience the applicant would obtain and the superiority of obtaining a qualification from Australia. However, there was no evidence about courses available in India that were similar to those undertaken by the applicant in Australia. Nor was there any evidence setting out why the applicant could not study in India (at [16]);
e)the applicant’s enrolment history was as follows (at [18]-[20]):
i)he was originally enrolled to study a Diploma of Business at the Perth Institute of Business and Technology and a Bachelor of Business at Edith Cowan University. He did not complete the Diploma and never started the Bachelor degree;
ii)he subsequently enrolled in a Certificate III and IV in Commercial Cookery at Kingston College but he did not complete the courses;
iii)he then enrolled in a Diploma of Management and completed that course on 16 December 2015. To date, that was the only course the applicant had completed;
iv)in 2016, the applicant enrolled in Certificate III and IV in Commercial Cookery at Empyrean Education Institute but he did not complete those courses;
v)the applicant then enrolled in a Certificate III and IV and Diploma of Hospitality and Management at Stanley College for 2017 and 2018 but, again, he did not complete those courses;
vi)he re-enrolled in a Certificate III and IV in Commercial Cookery at Global College for 2019 and 2020 but did not complete those courses; and
vii)he was enrolled in Commercial Cookery at New England College at the time of the hearing;
At [21]-[22], the Tribunal stated:
21. The Tribunal did ask him, at the hearing, to explain why he did not complete most of the courses and progress satisfactorily. He told the Tribunal in his oral evidence that he could not adapt to the environment when he first came to Australia and he could not understand and did not study on time. He found it hard. He was asked why he did not go back to India as he also said that he was unhappy in Australia and he did not have an answer for that question. It is unclear what the applicant did during his time as he was not undertaking study and he has enrolled in the same courses year after year without any progress .These matters cause serious concern to the Tribunal and significant weight is placed against the applicant’s case as the evidence indicates that the student visa programme is being used to circumvent the intentions of the migration programme
22. He stated that his parents did pay for the initial course but that he pays for the courses. His brother who is only 22 years of age is now employed in a restaurant as he has completed his courses and he has obtained a 485 Visa. The fact that his brother has been able to secure a visa to work in Australia creates doubt about the intention of the applicant as it would seem that he may also have a desire to remain in Australia to work, if he is able to complete his courses.
The Tribunal found the applicant’s testimony to be vague and unconvincing and was concerned about the amount of the time the applicant had been living in Australia (almost 5 and a half years) without “achieving much” and without progressing satisfactorily in any of the courses that he had been enrolled in (at [23]).
The Tribunal determined that the applicant’s present studies would only marginally improve his employment prospects in India and that the proposed further studies offered only limited incremental value, particularly alongside the experience the applicant had already gained in Australia.
The Tribunal also expressed concern that the applicant did not appear to have a strong desire to return to India. The Tribunal also determined that the applicant had not demonstrated how an overseas qualification would assist him in attaining his goals if he returned to India (at [24]-[25])
At [26]-[27], the Tribunal stated:
26. The Tribunal is not satisfied that the applicant isn’t simply proposing to study short and inexpensive courses in order to gain a student visa with the primary objective of maintaining ongoing residence.
27. The Tribunal considers that an applicant who is a genuine temporary entrant will have circumstances which support a genuine intention to remain in Australia temporarily, recognising the possibility that this may change over time to utilise lawful means to remain in Australia. Given the amount of time that the applicant has spent in Australia on student and bridging visas, without progressing satisfactorily, the Tribunal is concerned that a further student visa may be used primarily for maintaining ongoing residence.
The Tribunal then noted the lack of military service obligations and political or civil unrest in India (at [28]). It noted that there was nothing before the Tribunal regarding the applicant’s travel to any other country or to indicate that he had had visa refusals in any other country (at [29]). The Tribunal then referred to the factors in Direction 69 for which there was no evidence (at [30]).
The Tribunal concluded that it was not satisfied that the applicant intended genuinely to stay in Australia temporarily. Accordingly, it found that the applicant did not meet cl.500.212(a) of sch.2 of the Regulations (at [31]-[33]) and affirmed the delegate’s decision to refuse the visa.
Proceedings in this Court
The applicant’s judicial review application dated 2 December 2019 provides one ground of review as follows:
The Tribunal decision is not according to law. [Jurisdictional error].
The applicant was given an opportunity to file an amended application, any supporting affidavit evidence and an outline of written submissions. No further materials were filed.
The materials before the Court are thus limited to the judicial review application, a Court Book numbering 133 pages (marked as Exhibit 1) and outlines of written submissions filed by the Minister on
7 August 2020 and 4 September 2020.
The matter first came before the Court for hearing on 21 August 2020. On that occasion, the Court drew the Minister’s attention to the recent Federal Court authority in Eros v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 1061 (“Eros”). The Court asked the Minister to provide written submissions outlining whether Eros applied to the facts of this case. The applicant was given an opportunity to respond.
The Minister filed further written submissions on 4 September 2020. The applicant filed no further submissions.
The matter was then heard on 12 October 2020. The applicant appeared before the Court without legal representation. The Court confirmed with him that he had received a copy of the Court Book and both sets of the Minister’s written submissions.
Noting that the applicant was unrepresented, the Court gave him an opportunity to elaborate on, and further particularise, his sole ground of review and to advise the Court if there was anything else he thought that the Tribunal “did wrong”. This is now the standard procedure in this Court following the decision in Bala v Minister for Immigration & Border Protection [2019] FCA 600 at [7].
To assist the applicant, the Court explained that this Court can only turn its attention to the issue of jurisdictional error in the Tribunal’s decision. The Court explained that the possible categories of jurisdictional error are not exhaustive and sometimes overlap. For migration decisions of this sort, however, they most commonly include (but are not limited to) the following categories:
a)where the decision-maker identifies the wrong issue or asks the wrong question: Craig v State of South Australia (1995) 184 CLR 163 (“Craig”) at 198;
b)where the decision-maker ignores relevant material: Craig at 198;
c)where the decision-maker relies on irrelevant material: Craig at 198;
d)where the decision-maker fails to follow mandatory procedures: 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: SZRUI v Minister for Immigration, Multicultural Affairs & Citizenship [2013] FCAFC 80 at [2] (“SZRUI”); and
f)where the decision is illogical, irrational or unreasonable: Minister for Immigration & Citizenship v SZMDS (2010) 240 CLR 611 at [131]; Minister for Immigration & Citizenship v Li (2013) 249 CLR 332 at [26]-[28]; Minister for Immigration & Border Protection v Singh (2014) 231 FCR 437 at [44].
It was also explained that this Court cannot review the merits of the Tribunal’s decision or grant the visa that is sought. Rather, the role of the Court is restricted to determining if the Tribunal made a material error in arriving at the decision it arrived at: Minister for Immigration & Ethnic Affairs v Wu Shan Liang (1996) 185 CLR 259 at 272.
Unfortunately, the applicant was not able to assist the Court in relation to whether the Tribunal fell into jurisdictional error. Rather, he stressed the complexity of the visa process, his perception that the migration system was unfair and what he perceived as his own failings in relation to his educational history.
Consideration
Ground of Review
The applicant’s sole ground of review is, in effect, meaningless. It is little more than a bald assertion which fails to identify what the applicant thinks the Tribunal “did wrong”.
The Minister, quite rightly, noted his model litigant obligations and considered the Tribunal’s decision for any error. The Minister’s position is detailed in the written submissions dated 7 August 2020. The Court has also reviewed the Tribunal’s decision for error, noting the Court’s obligations as outlined in MZAIB v Minister for Immigration & Border Protection [2015] FCA 1392 (“MZAIB”).
Did the Tribunal provide procedural fairness?
In relation to whether the applicant was afforded “procedural fairness”, the Court is satisfied that the Tribunal complied with the obligations of div.5 of pt.5 of the Act. Specifically:
a)the Tribunal exercised its power pursuant to s.359(2) of the Act by inviting the applicant to provide information that was relevant to the criterion he was required to meet. Furthermore, the Tribunal gave the applicant an extension of time to provide that information;
b)having exercised the power pursuant to s.359(2) of the Act and having received information in response, the Tribunal was required to have regard to that information: the Act, s.359(1). Here, the Tribunal clearly had regard to the information provided in response to the invitation. It referred to the fact that it had been provided the information (at [6]) and its decision clearly references the information that arose from or was stated in the materials provided. For example, the Tribunal made reference to the applicant’s work history in Australia (at [13]), the fact that there were “general statements… about the desirability of the practical experience” (at [16]), the fact that the applicant worked on a farm with his father (at [17]) and the applicant’s study history (at [15]-[20]). All of these matters were detailed or referred to in the response to the s.359 invitation. The Tribunal clearly complied with the requirements of s.359(1);
c)the applicant was invited to, and did attend, a hearing before the Tribunal: the Act, s.360. There was no need for the Tribunal to give the applicant notice of the dispositive issue as it did not differ from the issue before the delegate: SZBEL v Minister for Immigration & Multicultural & Indigenous Affairs [2006] HCA 63. The applicant was assisted by his migration agent at the Tribunal’s hearing and the hearing record demonstrates that the hearing lasted for 30 minutes (CB 116-118). The Tribunal’s decision record notes the evidence that the applicant had provided in response to questions asked by the Tribunal (at [21]-[22]). There is nothing to suggest that the applicant was unable to meaningfully participate in the hearing;
d)it was unnecessary for the Tribunal to put any information to the applicant pursuant to ss.359A or 359AA. All of the information that the Tribunal had before it was information that had been provided by the applicant himself;
e)the applicant requested additional time to respond to the s.359 invitation and the Tribunal allowed more time. There is no other indication that the applicant, or his migration agent, requested additional time to provide information or asked for an adjournment of the hearing. Accordingly, there was no request made to the Tribunal for the exercise of a discretion; and
f)there is nothing in the materials before the Court to suggest that the Tribunal displayed actual or apprehended bias. The Tribunal carefully considered all of the applicant’s evidence and arguments and assessed those in a fair and impartial manner (as per Minister for Immigration v Jia Legeng (2001) 178 ALR 421 and SZRUI).
The Tribunal complied with its procedural fairness obligations. No error arises in relation to the conduct of the review.
Were the relevant legal principles applied correctly?
Noting that the Tribunal had refused the visa on the basis that the applicant did not meet cl.500.212(a) of the Act, the Court referenced the recent decision in Eros and asked the Minister to provide written submissions addressing whether the principles outline in Eros are relevant here.
As accurately summarised by the Minister (in written submissions dated 4 September 2020):
4.The Tribunal in the present matter, like the Tribunal in Eros, decided the matter only by reference to cl 500.212(a). The Federal Court in Eros found that cl 500.212(a) is concerned with an applicant’s genuine intention as to the length of her or his stay, and nothing else: Eros at [13]. The error that the Court identified in Eros in relation to the interpretation of cl 500.212(a) was that the Tribunal raised doubts about the primary or motivating purpose of the appellant staying in Australia, which it treated as relevant to the meaning of ‘temporary stay’ without making a finding that she intended to stay indefinitely in Australia. Instead the Tribunal found that the applicant genuinely intended to stay in Australia for a defined, relatively short period: Eros at [22].
5.The Federal Court’s decision in Eros needs to be read in the context of the specific factual circumstances which arose in that matter. The relevant facts in relation to the error in the approach to cl 500.212(a) include the following:
5.1.The Federal Court interpreted the Tribunal’s reasons as including a finding that the appellant intends to stay in Australia while her daughter is here, which, on the evidence before the Tribunal, was 2 years. The Federal Court considered that on any view 2 years was a temporary stay: Eros at [20]-[21]; and
5.2.The Federal Court considered that the Tribunal had raised doubts about the primary or motivating purposes of the appellant staying in Australia, which could be relevant in informing a finding that the appellant intended to stay indefinitely in Australia, but the Tribunal made no such finding: Eros at [22].
6. The Federal Court also found in Eros that some of the concerns expressed by the Tribunal about the appellant’s genuineness to stay as a student were insufficient to amount to findings, in relation to matters made relevant by cl 500.212(c), that the chapeau of cl 500.212 was not met. The Federal Court’s comments that are best seen as relating to cl 500.212(c) include the following:
[22] …There is no finding (though there are hints) that Ms Eros is not a genuine applicant to stay as a student. To make that finding the Tribunal would have to deal with other considerations beyond the intended length of stay, and evaluate her evidence including the fact, if it is the case, as it appears to be, that Ms Eros has dutifully undertaken the various courses that she has enrolled in, and, if it be the case, that she genuinely wants to do the courses.
…
[26]… If the kind of reasoning that is revealed by the Tribunal and the primary judge is to found the visa refusal, there has to be a treatment of the material whether by way of findings or conclusions as to the lack of satisfaction concerning matters such as whether the person is a genuine student or intends to undertake a course of study. That is, relevant findings or consideration need to be made or undertaken, based on considerations made relevant by subcl 500.212(c), to the effect that the chapeau is not met. That was not done. Matters were hinted at. But the reasoning was based on Ms Eros not intending to stay temporarily, when the factual finding was such that she was intending to stay temporarily.
The Tribunal’s error in Eros was that it raised doubts and concerns about the appellant’s motivation/reason for staying in Australia (i.e., to be with her daughter) but did not make a finding that this signified an intention to remain indefinitely in Australia. Rather, the Tribunal found that the applicant intended to stay for at least two years – an arguably temporary period of time.
Here, unlike in Eros, the Tribunal made no finding that the applicant intended to stay for, at least, a temporary period of time. Rather (reading the Tribunal’s reasons as a whole), it is clear that the Tribunal had a number of concerns about why the applicant applied for the visa and ultimately determined that he had no incentive to return. Concerns about an applicant’s purpose in applying for a visa can be relevant to inform a finding that an applicant does not intend to stay “temporarily”: Eros at [22].
In this matter, the Tribunal stated that:
a)although the applicant still had ties to India, his brother and other individuals in Australia presented a strong incentive for him to remain in Australia (at [15]);
b)the lack of course progress raised serious concern that the student visa programme was being used to circumvent the intentions of the migration programme (at [21]);
c)it had “doubts” about the applicant’s intentions as it seemed that he had a desire to remain in Australia to work (at [22]);
d)it was concerned with the amount of time that the applicant had been living in Australia (five and a half years) without achieving “very much” and without progressing satisfactorily in any of the courses that he had enrolled in (at [23]); and
e)the applicant appeared not to have a strong desire to return to India (at [25]).
Cumulatively, these findings led the Tribunal to conclude as follows:
26. The Tribunal is not satisfied that the applicant isn’t simply proposing to study short and inexpensive courses in order to gain a student visa with the primary objective of maintaining ongoing residence.
Section 65 requires the Tribunal be positively satisfied that the applicant genuinely intended to stay temporarily. Here, the Court agrees with the Minister that [26] in the Tribunal’s decision constitutes a clear and unequivocal finding that the applicant did not genuinely intend to stay temporarily. There is no reference, anywhere in the Tribunal’s decision, to a finite or temporary period, as was the case in Eros.
The Court also notes the Minister’s further comments in written submissions about the effect of [27] of the Tribunal’s decision, as follows:
9.The Minister acknowledges the following ‘concern’ expressed by the Tribunal in the final sentence of [27]:
Given the amount of time that the applicant has spent in Australia on student and bridging visas, without progressing satisfactorily, the Tribunal is concerned that a further student visa may be used primarily for maintaining ongoing residence.
10.The similarity of this concern to that expressed in the final sentence of the Tribunal’s reasons in the decision in Eros (see the Federal Court’s Eros judgment at [20]) should not trouble the Court in the present matter. That concern was found not to amount to a finding in Eros (see [30]), and the Minister does not submit that it amounts to a finding here. However, the difference between the 2 cases is that in the present matter, there is no finding that the applicant intended to remain in Australia only for a finite period (as there was in Eros). Here, rather, the ‘concern’ expressed at [27] is part of the reasons for the clear finding expressed at [26] as to the Tribunal’s lack of satisfaction that the applicant had a genuine intention to remain in Australia temporarily.
11.Likewise, the concerns about the applicant’s intentions expressed at paragraphs [21], [22], [23] and [25] all form part of the reasoning as to why the Tribunal found at [26] that it was not satisfied that the applicant was not enrolling in short inexpensive courses simply to maintain ongoing residency. The Federal Court in Eros expressly recognised at [22] that concerns about an applicant’s purpose can be relevant to cl 500.212(a) if they inform a finding that the applicant intended to stay indefinitely in Australia. That is essentially what the Tribunal has done in the present matter. Further, the matters considered by the Tribunal and which led to the Tribunal’s various concerns are matters that it was appropriate for the Tribunal to take into account in accordance with subparagraphs cl 500.212(a)(i), (ii) and (iv) and Direction No 69.
The Court agrees with Minister’s analysis above.
In Eros, the reason the Chief Justice specifically referenced the “concern” was because there had not been a definitive finding that the applicant was not intending to stay temporarily. There was, however, a clear finding that she intended to stay for a (limited) two-year period.
Here, there is no reference to a finite or temporary period of time. There is, however, a clear determination that the visa was being used as means to maintain ongoing residence (at [26]).
Concerns of the sort addressed by Chief Justice Allsop in Eros do not arise within the context of [27] here. Given that the Tribunal had already made a clear finding at [26], the “concern” expressed at [27] can only be seen to have strengthened the Tribunal’s finding that the applicant was using the visa to maintain ongoing residency.
The Tribunal correctly applied cl.500.212(a) and took into account all relevant considerations to come to a logical and reasoned conclusion.
Conclusion
The judicial review application fails to identify any jurisdictional error. The Court is otherwise satisfied that no error arises.
The application is, accordingly, dismissed.
I certify that the preceding forty-nine (49) paragraphs are a true copy of the reasons for judgment of Judge Kendall
Associate:
Date: 15 October 2020
Key Legal Topics
Areas of Law
-
Administrative Law
-
Immigration
Legal Concepts
-
Judicial Review
-
Jurisdiction
-
Procedural Fairness
3
14
3