Staff Services Employment Pty Ltd (Migration)

Staff Services Employment Pty Ltd (Migration) [2019] AATA 3303 (24 July 2019)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANT:  Staff Services Employment Pty Ltd
CASE NUMBER:  1902398
DIBP REFERENCE(S):  BCC2017/2313443
MEMBER:Terrence Baxter
DATE:24 July 2019
PLACE OF DECISION:  Brisbane
DECISION:The Tribunal sets aside the decision under review and substitutes a decision approving the nomination.
Statement made on 24 July 2019 at 10:57am
CATCHWORDS
MIGRATION – nomination – Direct Entry Nomination stream – position not genuine – position is a related entity of applicant – evidence provided – decision under review set aside

LEGISLATION
Migration Act 1958 (Cth), ss s 245AR(1)
Migration Regulations 1994 (Cth), r 1.13A, 1.13B, 5.19

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 Immigration on 16 January 2019 to reject the applicant’s application for approval of the nomination of a position in Australia under r.5.19 of the Migration Regulations 1994 (the Regulations).
The applicant Staff Services Employment Pty Ltd applied for approval on 29 June 2017. The applicant nominated Mr Quan Vinh Truong (the nominee) in the position of Executive Chef. The requirements for the approval of the nomination of a position in Australia are found in r. 5.19 of the Regulations which contains two alternative streams: a Temporary Residence Transition nomination (r. 5.19(3)) stream and a Direct Entry nomination (r. 5.19(4)) stream. If the application is made in accordance with r. 5.19(2) and meets the requirements of either stream, then the application must be approved. If any of the requirements are not met then the application must be refused: r. 5.19(5).
In this case, the applicant has applied for approval of a nomination, seeking to satisfy the criteria in the Direct Entry Nomination stream.
The delegate refused the application on the basis the applicant’s nomination did not satisfy r. 5.19(4)(a)(ii) of the Regulations because the applicant does not have a need to employ a paid employee to work in the position under the applicant’s direct control and also that the nomination did not satisfy r. 5.19(4)(b)(ii) because the nominator does not directly operate the business in which the nominated position exists.
Mr Godfrey Mantle, the sole director and shareholder of the applicant company appeared before the Tribunal on 26 June 2019 to give evidence and present arguments. At the request of the applicant, the hearing was conducted jointly with Case Number 1721235 involving the same applicant and similar issues.
The applicant was represented in relation to the review by its registered migration agents. The representatives attended the Tribunal hearing.
For the following reasons, the Tribunal has decided to set aside the decision under review and substitute a decision approving the nomination.
CONSIDERATION OF CLAIMS AND EVIDENCE
The issue in this case is whether the applicant meets the requirements for approval of the nomination under the Direct Entry nomination stream set out in r. 5.19(4), which is extracted in the attachment to this decision. For the nomination to be approved, all the requirements must be met.
Evidence presented before the hearing
A large number of documents and submissions were presented to the Department in support of the application. These included various company documents, financial statements, Activity Statements and taxation returns, an Organisational Chart for the Mantle group of companies Mantle Group Hospitality (of which the applicant company forms part), a Letter of Appointment and an Employment Contract – Salary Agreement between the applicant and the nominee, and documents detailing the nature and extent of the business activities of the companies within Mantle Group Hospitality.
Evidence presented at the hearing
On the morning of the hearing, the applicant produced a statutory declaration by Mr Godfrey Mantle on behalf of the applicant which details the history of development of companies within Mantle Group Hospitality and the share structure and directorships of those companies. During the hearing, the applicant produced further company documents, financial statements and taxation returns, evidence of training expenditure and submissions. During the hearing, the Tribunal invited the applicant to provide further information regarding the control of companies within Mantle Group Hospitality.
Evidence presented after the hearing
Subsequent to the hearing, the applicant produced a further statutory declaration by Mr Mantle, the company constitution for the company Jimmy’s on the Mall Pty Ltd, an Organisational chart for Mantle Group Hospitality and further submissions.
The application is compliant: r. 5.19(4)(a)
Regulation 5.19(4)(a) requires that the application for approval must be in the approved form, must be accompanied by the prescribed fee, and, where applicable, must include the required written certification relating to conduct that contravenes s.245AR(1) of the Migration Act 1958 (the Act). The application must also identify a need for the nominator to employ a paid employee to work in the position under their direct control.
Having regard to the information provided by the Department, the Tribunal is satisfied that the application for approval was made on the approved form, was accompanied by the prescribed fee and included a written certification stating whether the applicant had engaged in conduct in relation to the nomination that contravenes s. 245AR(1).The requirements of r. 5.19(2) and consequently of r. 5.19(4)(a)(i) are met.
The delegate was not satisfied that the application identified a need for the applicant to employ a paid employee to work in the position of Executive Chef under the applicant’s direct control.
It is unclear whether this requirement is directed just at a statement to this effect or something of a more qualitative nature. The wording ‘identifies a need’ arguably suggests more is required to meet this criterion than simply a statement or declaration that there is such a need. ‘Identify’ is defined as ‘to recognise or establish as being a particular person or thing; attest or prove to be as claimed or asserted.’[1] On that view, which is consistent with that reflected in Departmental policy,[2] a decision maker would need be satisfied there is a genuine need on the part of the nominator to employ someone in the nominated position.[3] However, it could alternatively be argued that r.5.19(4)(a) as a whole is directed towards requirements for the application form / process of a more administrative nature, such that r.5.19(4)(a)(ii) could be met by a simple statement or certification of need. Support for this view can also be found in the contrast between the wording of r.5.19(4)(a)(ii) and, for example, r.5.19(4)(h)(ii)(B) (for applications relating to positions in regional Australia), which requires that there be a genuine need for the nominator to employee a paid employee to work in the position under the nominator’s control – clearly requiring a qualitative assessment, and r. 5.19(4)(d)(i), which requires satisfaction that the employee will be employed on a full-time basis in the position for at least two years. Given the uncertain scope of r. 5.19(4)(a)(ii), and the requirement in relation to this application to satisfy r. 5.19(4)(d)(i), the Tribunal considers that this issue is more appropriately considered under r. 5.19(4)(d)(i) later in these Reasons.
[1] Macquarie Dictionary online (accessed 9 March 2017).
[2] PAM3: Migration Regulations – Divisions – Div 5.3 – General > Approval of nominated positions (employer nomination) > Part C - Criteria applicable to Direct Entry stream nominations > Need for a paid employee > Applicability and overview (reissued 12/05/17 – last reissue prior to 1 July 2017).
[3] In Bharaj Construction Pty Ltd v MIBP [2016] FCCA 902 (Judge Barnes, 28 April 2016), the Court considered a similarly worded provision in respect of a pre-1 July 2012 RSMS nomination, i.e. “the employer nomination is made by an employer in respect of a need for a paid employee”. Whilst on the one hand r.5.19(4)(a)(ii) does not appear to impose a different requirement beyond emphasising the requirement for an applicant to identify the need (unlike the pre-1 July 2012 version of r.5.19(2)(a) and (4)(a)), the wording of the criteria does differ slightly and the Tribunal exercises caution in applying the reasoning of Bharaj to a post-1 July 2012 nomination as is currently being considered.
The Tribunal considers that r. 5.19(4)(a)(ii) is more directed to the administrative process, consistent with the requirements of r. 5.19(4) as a whole. The nomination application, on page 4 of that document, identifies that the position to be filled is that of Executive Chef. At the hearing, Mr Mantle gave evidence of the need to engage qualified staff to fill executive chef roles at venues operated by the Mantle group of companies.
The applicant is a member of the Mantle group of companies, Mantle Group Hospitality. The applicant produced several documents and submissions to the Tribunal regarding the development of the Mantle Group Hospitality organisational structure. Mr Mantle gave evidence at the hearing regarding this issue. He said that the first operating company was Jimmy’s on the Mall Pty Ltd. When they planned to open a new venue, they received legal and accounting advice to incorporate a new company to operate that venue. This was for asset protection and risk minimisation purposes. Further new companies were formed as further venues were established.
The group found that this structure presented problems when an employee worked for two different companies within the group. The employee was unable to claim the tax-free threshold for the second employer and was thus penalised for taxation purposes. The applicant Staff Services Employment Pty Ltd was formed to employ staff for all operating venues within the group. This achieved administrative efficiency for both the group and the staff by facilitating the ease with which the staff could move within the various venues and reduced administrative paperwork. The arrangement resulted in a high staff retention rate. The nominee is presently employed by the applicant.
The nominated position is Executive Chef. The application states that that the trading venue is Jimmy’s on the Mall Restaurant and Bar. At the hearing, Mr Mantle confirmed that the nominee does work and will work at Jimmy Lee’s Brisbane. This venue is listed under the name of the company Jimmy’s on the Mall Pty Ltd (Jimmy’s) in the Organisational Chart. ASIC documents produced to the Tribunal establish that Mr Godfrey Mantle is the sole shareholder and director of the applicant Staff Services Employment Pty Ltd. ASIC documents also presented to the Tribunal show that Mr Mantle is the sole director of Jimmy’s and that he is the holder of 50% of the ordinary shares of that company. There are also DD class, EE class, FF class, GG class, HH class, II class and JJ class shares issued in the company. The company constitution provides that those classes of shares do not have voting rights and accordingly only the ordinary shares have voting rights at general meetings of the company. Clause 17.7 of the constitution also provides that in the case of equality of votes, Mr Mantle, whilst he remains a shareholder of the company will have a casting vote in addition to his deliberative vote. Accordingly, the Tribunal finds that Mr Mantle controls both companies and that the two companies are associated entities within the meaning of the Corporations Act.
At the hearing, Mr Mantle contended that Jimmy’s did not operate the Jimmy Lee’s Brisbane venue. He contended that Jimmy’s was merely the lessee of the premises and suggested that the applicant, as employer of all of the employees at the venue, was the actual operator. He conceded that the operating income from business operations at the venue was received by Jimmy’s and that Jimmy’s paid the applicant a service fee for the provision of staff. Having regard to all of the evidence, the Tribunal finds that Jimmy’s operates that venue, where the nominated position exists.
The delegate found that a nominator cannot nominate a position that exists within the business activities of an associated entity under the Direct Entry Stream. This finding was taken from Departmental policy dealing with r. 5.19(4)(a)(ii) and r. 5.19(4)(b)(ii). The requirements of the former of these regulations are set out in paragraph 12 above. The requirements of the latter of the regulations are that the nominator is actively and lawfully operating a business in Australia and directly operates the business (this requirement being dealt with in following paragraphs of these Reasons). Although the Tribunal can have regard to Departmental policy, it is not binding on the Tribunal. In the present case, the Tribunal has given careful consideration to the policy, but, for the reasons set out in the following paragraphs, the Tribunal finds that the requirements of r. 5.19(4)(a)(ii) are met.
The Tribunal has found that Jimmy’s is a related entity of the applicant. The business of the applicant is that of providing staff to related businesses within Mantle Group Hospitality, including Jimmy Lee’s, Brisbane. The Tribunal accepts that the applicant has a need to employ executive chefs to place in venues within the group to satisfy the operating needs of those venues. Mr Mantle gave evidence that the applicant monitors the performance of all of its employees, wherever placed. The Tribunal considers that the ability to hire, dismiss and discipline its employees demonstrates that all employees, including the nominee, are under the direct control of the applicant.
The Tribunal is therefore satisfied that the application for approval identifies a need to employ a paid employee in the position of Executive Chef under the applicant’s direct control such that r.5.19(4)(a)(ii) is met. The Tribunal will consider later in these Reasons whether the applicant has established that the nominee will be employed on a full-time basis in the position for at least two years to satisfy the requirements of r. 5.19(4)(d)(i).
Accordingly, as both r. 5.19(4)(a)(i) and r. 5.19(4)(a)(ii) are satisfied, the requirement in r.5.19(4)(a) is met.
Nominator is actively and lawfully operating a business in Australia: r.5.19(4)(b)
Regulation 5.19(4)(b) requires that applicant is actively, lawfully and directly operating a business in Australia.
The applicant produced to the Tribunal ASIC documents, taxation returns, Activity Statements and various financial statements. Mr Mantle gave evidence of the current business activities of the applicant in Brisbane. The financial statements and taxation return for the applicant for the 2017/2018 financial year disclose a gross income of $23,055,426. Having regard to all of the evidence, the Tribunal is satisfied that the applicant is actively, lawfully and directly operating a business, namely a staff employment company, in Australia.
Accordingly, the requirement in r. 5.19(4)(b) is met.
Position is not labour-hire: r. 5.19(4)(c)
Regulation 5.19(4)(c) applies to nominators whose business activities include those relating to labour hire to an unrelated business. In these cases, the nominated position must be within the business activities of the nominator.
It appears to be the case that the business of the applicant is the provision of staff to venues operating within Mantle Group Hospitality. Mr Mantle gave evidence that the applicant does not provide staff to unrelated businesses. This is supported by the Organisational Chart and ASIC documents provided to the Tribunal. If the applicant is a labour-hire company for the purposes of r. 5.19(4)(c), the Tribunal finds that it is labour hire to related businesses
Accordingly, the requirement in r. 5.19(4)(c) does not apply.
Term of employment of the visa holder: r. 5.19(4)(d)
Regulation 5.19(4)(d) requires the nominee to be employed in the nominated position for at least two years full time, and the terms and conditions of that employment do not expressly exclude the possibility of an extension.
The Department’s file includes a Letter of Appointment between the applicant and the nominee dated 14 June 2017 and a Salary Agreement in accordance with the Staff Services Pty Ltd Certified Workplace Agreement 2000. These documents provide that the nominee’s employment is to commence on the date of the grant of his Subclass 186 visa and continue for a period of five years. The agreement does not include an express exclusion of the possibility of extending the period of employment. Regulation 5.19(4)(d)(ii) is therefore satisfied.
The Profit and Loss statement for the 2017/2018 financial year for the applicant which was produced to the Tribunal discloses that the applicant had a trading income of $23,055,426 for the year, an increase from $14,945,806 in the previous year. The 2018 figures are supported by the copy of signed taxation return supplied to the Tribunal. The Profit and Loss statement is included in a set of Financial Statements prepared by the applicant’s Chartered Accountants.
Evidence was presented to the Tribunal that the nominee has been employed in the nominated position since about the time of the signing of the employment documents in 2017.
Having regard to the evidence provided by the applicant, the Tribunal is satisfied that the applicant has the financial capacity to employ the nominee in the position of Executive Chef for two years on a full-time basis in accordance with the Letter of Appointment and Salary Agreement and that the nominee will be employed on a full-time basis in that position for at least two years. Regulation 5.19(4)(d)(i) is therefore satisfied.
The Tribunal having found that both r. 5.19(4)(d)(i) and (ii) are met, accordingly, the requirement in r. 5.19(4)(d) is met.
No less favourable terms and condition of employment: r. 5.19(4)(e)
Regulation 5.19(4)(e) requires that the terms and conditions of employment applicable to the nominated position will be no less favourable than those that are, or would be, provided to an Australian citizen or permanent resident performing equivalent work in the same workplace at the same location.
The Letter of Appointment and Salary Agreement provide for a salary of $182,000 per annum to be paid to the nominee, plus superannuation. At the hearing, Mr Mantle gave evidence that this salary is significantly in excess of what might be payable to an Australian citizen or permanent resident. He stated that, although it is more expensive to employ overseas chefs, it was impossible to find local chefs in the specialty area. Some local staff would only work if their wages were paid in cash, which the applicant refuses to do. He said that the only way to get skilled staff was to nominate them. This costed more, but delivered more in terms of quality and stability.
Job portal PayScale reveals that salaries for executive chefs in Brisbane currently range from $55,000 to $108,000, with an average salary of $80,444. The portal Indeed refers to a salary range of $43,000 to $176,000, with an average of $98,403 and positions currently advertised in the range $96,000 to $120,000.
Based on the evidence available, the Tribunal is satisfied that the terms of employment applicable to the nominee are no less favourable than the terms and conditions which would be provided to an Australian citizen or Australian permanent resident for performing such work in that workplace at that location.
Accordingly the requirements of r. 5.19(4)(e) are met.
No adverse information known to Immigration: r. 5.19(4)(f)
Regulation 5.19(4)(f) requires that there is no adverse information known to Immigration about the nominator or person associated with the nominator; or it is reasonable to disregard any such information. For these purposes, ‘adverse information’ and ‘associated with’ have the meaning given in rr.1.13A and 1.13B.

There is no evidence before the Tribunal that there is any adverse information of the type described in the relevant definitions known to the Department about the applicant or any associated person.
Accordingly the requirements of r. 5.19(4)(f) are met.
Satisfactory compliance with workplace relations laws: r. 5.19(4)(g)
Regulation 5.19(4)(g) requires that the applicant has a satisfactory record of compliance with the laws of the Commonwealth, and of each State or Territory in which the applicant operates a business and employs employees in the business, relating to workplace relations.
There is no evidence before the Tribunal to suggest that the applicant has an unsatisfactory record of compliance with workplace relation laws of the Commonwealth or any State or Territory in which the applicant operates a business. The Tribunal is satisfied that the applicant does have a satisfactory record of compliance.
Accordingly the requirements of r. 5.19(4)(g) are met.
Tasks of the position genuine need for the position and training requirements r. 5.19(4)(h)
Regulation 5.19(4)(h) contains a number of alternative requirements. These are set out in detail in the attachment to the decision but can be briefly summarised as requiring either that:
·the tasks to be performed in the position will be performed in Australia and correspond to those of an occupation specified by the Minister (see legislative instrument IMMI 16/059, the occupation is applicable to the proposed employee in accordance with any specifications made in that instrument, and specified training requirements are met; or
·the position and nominator’s business is located in regional Australia, there is a genuine need for the paid position under the nominator’s direct control which cannot be filled by a locally resident Australian citizen or permanent resident, the tasks of the position correspond to those of an occupation specified in the relevant legislative instrument, the occupation is applicable to the proposed employee in accordance with the specification of the occupation and that a regional certifying body has advised the Minister about certain matters relating to the position.
The nomination relates to a position in non-regional Australia and the Tribunal has considered whether the applicant can meet both of the requirements in r. 5.19(4)(h)(i).
Regulation 5.19(4)(h)(i)(A) - the tasks to be performed in the position will be performed in Australia and correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph
The position nominated by the applicant was Executive Chef and the Occupation was listed as Chef ANZSCO classification 351311. The tasks specified in ANZSCO for that occupation are as follows :
The tasks of the nominee set out in the employment documents produced to the Tribunal and described at the hearing by Mr Mantle are consistent with the tasks specified in ANZSCO. Based on all the evidence, the Tribunal is satisfied that the tasks to be performed in the position correspond to the tasks of the occupation of Chef specified by the Minister in the relevant instrument, being IMMI 16/059. There is a caveat attached to the position in the instrument, namely that for a nomination or visa application for a Subclass 186 visa, the occupation of Chef excludes positions in Fast Food or Takeaway Food Service. The Tribunal is satisfied that the caveat does not apply in the present matter. Accordingly, the requirements of r. 5.19(4)(h)(i)(A) are met.
Regulation 5.19(4)(h)(i)(B)(I) – the nominator’s business has operated for at least 12 months, and the nominator meets the requirements for the training of Australian citizens and Australian permanent residents that are specified by the Minister in an instrument in writing for this sub-sub-subparagraph
The applicant produced financial statements to establish that the applicant has been operating its business since at least the 2013 financial year. At the hearing, Mr Mantle gave evidence that the applicant has been operating since 1999. The training benchmarks and training requirements are specified in instrument IMMI 13/030. The business is required to show that training that has been, and continues to be, provided to employees who are Australian citizens and Australian permanent residents is related to the purpose of the business. The business is also required to outlay recent expenditure to the equivalent of at least 1% of payroll of the business in the provision of training of employees of the business.
The documents produced to the Tribunal establish that Mantle Group Hospitality includes the company Mayfair College Pty Ltd. This entity is an Enterprise Registered Training Organisation accredited by the Australian government in 2005. It provides training to qualified staff of the applicant, including Australian citizens and Australian permanent residents, to Diploma level. Mr Mantle gave evidence at the hearing that the College has in the past provided training to some prospective employees of the applicant who were Australian citizens or residents, but that only current staff were being trained at the present time. Training is provided in various courses in Hospitality, Management, Responsible Service of Alcohol, Business Administration, Events and Responsible Management of Licensed Venues. Mr Mantle also gave evidence at the hearing regarding the operations of the College.
All staff of Mayfair College Pty Ltd are paid by the applicant. The applicant produced evidence supported by accompanying spreadsheets that in the 2018 financial year, the applicant paid wages amounting to $553,629.15 for training staff. The total payroll of the applicant for that year was $23,078,743. The expenditure on training amounts to 2.39% of the total payroll. The specifications in IMMI 13/030 provide that expenditure that can count towards this benchmark includes employment of a person who trains Australian employees who are Australian citizens and Australian permanent residents as a key part of their job. Accordingly, the Tribunal is satisfied that r. 5.19(4)(h)(i)(B)(I) is met.
Having regard to the above findings, accordingly the requirements of r. 5.19(4)(h) are met.
Based on the findings above, the Tribunal is satisfied that the applicant meets the requirements of r.5.19 for approval of the nomination of the position in Australia.
DECISION
The Tribunal sets aside the decision under review and substitutes a decision approving the nomination.
Terrence Baxter
Member

ATTACHMENT - EXTRACTS FROM THE MIGRATION REGULATIONS 1994
5.19Approval of nominated positions (employer nomination)
…
(2)The application must:
(a)be made in accordance with approved form 1395…; and
(aa) include a written certification by the nominator stating whether or not the nominator has engaged in conduct, in relation to the nomination, that constitutes a contravention of subsection 245AR(1) of the Act; and
(b)be accompanied by the fee mentioned in regulation 5.37.
…
Direct Entry nomination
(4)The Minister must, in writing, approve a nomination if:
(a)the application for approval:
(i)       is made in accordance with subregulation (2); and
(ii)      identifies a need for the nominator to employ a paid employee to work in the position under the nominator’s direct control; and
(b)the nominator:
(i)       is actively and lawfully operating a business in Australia; and
(ii)      directly operates the business; and
(c)for a nominator whose business activities include activities relating to the hiring of labour to other unrelated businesses — the position is within the business activities of the nominator and not for hire to other unrelated businesses; and
(d)both of the following apply:
(i)       the employee will be employed on a full-time basis in the position for at least 2 years;
(ii)      the terms and conditions of the employee’s employment will not include an express exclusion of the possibility of extending the period of employment; and
(e)the terms and conditions of employment applicable to the position will be no less favourable than the terms and conditions that:
(i)       are provided; or
(ii)      would be provided;
to an Australian citizen or an Australian permanent resident for performing equivalent work in the same workplace at the same location; and
(f)either:
(i)       there is no adverse information known to Immigration about the nominator or a person associated with the nominator; or
(ii)      it is reasonable to disregard any adverse information known to Immigration about the nominator or a person associated with the nominator; and
(g)the nominator has a satisfactory record of compliance with the laws of the Commonwealth, and of each State or Territory in which the applicant operates a business and employs employees in the business, relating to workplace relations; and
(h)either:
(i)       both of the following apply:
(A)the tasks to be performed in the position will be performed in Australia and correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;
(AAA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;
(B)either:
(I)the nominator’s business has operated for at least 12 months, and the nominator meets the requirements for the training of Australian citizens and Australian permanent residents that are specified by the Minister in an instrument in writing for this sub-sub-subparagraph; or
(II)the nominator’s business has operated for less than 12 months, and the nominator has an auditable plan for meeting the requirements specified in the instrument mentioned in sub-sub-subparagraph (I); or
(ii)      all of the following apply:
(A)the position is located in regional Australia;
(B)there is a genuine need for the nominator to employ a paid employee to work in the position under the nominator’s direct control;
(C)the position cannot be filled by an Australian citizen or an Australian permanent resident who is living in the same local area as that place;
(D)the tasks to be performed in the position correspond to the tasks of an occupation specified by the Minister in an instrument in writing for this sub-subparagraph;
(DA)the occupation is applicable to the person identified under subparagraph (a)(ii) in accordance with the specification of the occupation;
(E)the business operated by the nominator is located at that place;
(F)a body that is:
(I)specified by the Minister in an instrument in writing for this sub-subparagraph; and
(II)located in the same State or Territory as the location of the position;
has advised the Minister about the matters mentioned in paragraph (e) and sub-subparagraphs (B) and (C).

[2019] AATA 3303

24 July 2019

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Statutory Construction

Procedural Fairness

Remedies