Suleiman v Minister for Immigration and Border Protection
[2018] FCA 594
•2 May 2018
FEDERAL COURT OF AUSTRALIA
Suleiman v Minister for Immigration and Border Protection [2018] FCA 594
File number: WAD 547 of 2017 Judge: COLVIN J Date of judgment: 2 May 2018 Catchwords: MIGRATION - application to review decision of Administrative Appeals Tribunal - original decision by delegate of Minster not to revoke mandatory cancellation of visa under s 501CA - whether jurisdictional error in Tribunal treating some considerations under Direction 65 as secondary considerations - whether a direction under s 499 could require some considerations to be treated as secondary considerations in all cases - jurisdictional error found - whether a suppression order should be made Legislation: Administrative Appeals Tribunal Act 1975 (Cth) ss 43C(c), 44(2A)
Migration Act 1958 (Cth) ss 65, 476, 476A, 499, 500, 500(6K), 501(3A), 501CA
Cases cited: BCR16 v Minister for Immigration and Border Protection [2017] FCAFC 96; (2017) 248 FCR 456
Bochenski v Minister for Immigration and Border Protection [2017] FCAFC 68; (2017) 250 FCR 209
Chen v Migration Agents Registration Authority (No 1) [2016] FCA 649
Goundar v Minister for Immigration and Border Protection [2016] FCA 1203
Graham v Minister for Immigration and Border Protection [2017] HCA 33
Re Becker; Ex parte Minister for Immigration and Ethnic Affairs (1977) 15 ALR 696
Wei v Minister for Immigration and Border Protection [2015] HCA 51; (2015) 257 CLR 22
Whittaker v Minister for Immigration and Border Protection [2017] FCA 494
Williams v Minister for Immigration and Border Protection [2014] FCA 674; (2014) 226 FCR 112
Date of hearing: 20 April 2018 Registry: Western Australia Division: General Division National Practice Area: Administrative and Constitutional Law and Human Rights Category: Catchwords Number of paragraphs: 52 Counsel for the Applicant: The Applicant appeared in person Counsel for the First Respondent: Ms SJ Oliver Solicitor for the First Respondent: Sparke Helmore Lawyers Counsel for the Second Respondent: The Second Respondent filed a submitting notice
Table of Corrections 29 June 2018 In the last sentence in paragraph 48 the word 'was' has been deleted. 29 June 2018 In paragraph 7(8) a quotation mark has been added before 'it'. ORDERS
WAD 547 of 2017 BETWEEN: RASHID ALI SULEIMAN
Applicant
AND: MINISTER FOR IMMIGRATION AND BORDER PROTECTION
First Respondent
ADMINISTRATIVE APPEALS TRIBUNAL
Second Respondent
JUDGE:
COLVIN J
DATE OF ORDER:
2 MAY 2018
THE COURT ORDERS THAT:
1.The name of the applicant be amended to Rashid Ali Suleiman.
2.The time within which the application may be brought be extended so as to allow the application to be heard.
3.The decision of the Administrative Appeals Tribunal dated 22 September 2017 be set aside and the matter be remitted to the Tribunal for reconsideration according to law.
4.The first respondent do pay the applicant's costs of the application excluding the costs of the application for an extension of time to be assessed if not agreed.
Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
REASONS FOR JUDGMENT
COLVIN J:
Mr Suleiman arrived in Australia in 2004 as an unaccompanied minor stowaway aged 16. He remained in Australia as the holder of a global special humanitarian visa. In 2016, he was convicted of offences committed at the home of his former partner. He had set fire to a car in the carport, broken his way into the home, smashed numerous items of property and forced his way into a bedroom where his former partner and their two children had taken refuge. He also forcibly removed one of the children from the home, but when outside was persuaded by neighbours to hand over the child to them.
Mr Suleiman was sentenced to two years of imprisonment for each of two offences (one relating to the fire and the other relating to the burglary and criminal damage to property) with the terms to be served concurrently. He had been convicted previously of other offences, but had not been sentenced to a term of imprisonment. A charge of threat to injure, endanger or harm a person in 2010 had been dismissed in 2011 due to unsoundness of mind.
Under s 501(3A) of the Migration Act 1958 (Cth), the Minister must cancel a visa if the Minister is satisfied that (a) the holder has been sentenced to a term of imprisonment totalling 12 months or more; and (b) the holder is serving a sentence of imprisonment on a full-time basis for an offence against an Australian law. Mr Suleiman's visa was cancelled by a delegate of the Minister in performance of that statutory duty.
Where a visa is cancelled in such circumstances, the Minister must give written notice of the decision setting out certain specified relevant information and invite the person to make representations to the Minister: s 501CA(3). Where representations are made, the Minister may revoke the original decision if, relevantly for present purposes, the Minister is satisfied that there is a reason why the original decision should be revoked: s 501CA(4)(b). The applicant made representations in accordance with the Minister's invitation. One of the matters raised by the applicant was the risk of harm to him if he was returned to his country of nationality.
A delegate of the Minister decided that the original decision should not be revoked.
Mr Suleiman then applied to the Administrative Appeals Tribunal to review the non‑revocation decision. The Tribunal has jurisdiction to review a decision of a delegate of the Minister under s 501CA(4): s 500(1)(ba). The Minister has power under s 499 of the Migration Act to give written directions to 'a person or body having functions or powers under this Act' that are not inconsistent with the Act. In undertaking the review provided for by s 500(1)(ba), the Tribunal is such a 'body' and directions under s 499(1) are binding on Tribunal members 'as an overt fetter on discretion': Bochenski v Minister for Immigration and Border Protection [2017] FCAFC 68; (2017) 250 FCR 209 at [65]. The Minister has given such a direction in respect of the exercise of various powers including the power under s 501CA(4): Direction No 65 - Visa refusal and cancellation under s 501 and revocation of a mandatory cancellation of a visa under s 501CA (Direction 65).
The decision of the Tribunal
The Tribunal decided to affirm the non‑revocation decision. In doing so it considered Mr Suleiman's claims in detail and concluded, amongst other things, that:
(1)the offences described above were extremely serious; they 'were violent and committed against his own vulnerable children and a partner who was clearly, on the evidence, terrified and in fear for her own safety and the safety of her young children' (at [55]);
(2)the applicant suffers from paranoid schizophrenia which is much worse when he uses illicit drugs and when he consumes excessive amounts of alcohol (at [66]);
(3)while in prison the applicant participated in, but did not complete, various rehabilitation programs (at [65]);
(4)the applicant has expressed considerable remorse for his past conduct and now admits he needs medical intervention (at [67]);
(5)'without medical intervention, coupled with programs aimed at tackling drug and alcohol abuse, his mental health will deteriorate' (at [71]);
(6)the applicant's crimes are so serious 'that any risk of re‑offending is completely unacceptable' and there remains a risk of re-offending 'due to the nature of his combined mental health and addiction issues' (at [72]);
(7)'the children and their mother now live in an undisclosed location because of the violence they experienced at the hands of [the applicant]' (at [74]);
(8)'it is not in the best interests of the applicant's children for the decision to cancel his visa to be revoked' (at [83]);
(9)the expectations of the Australian community are that a non-citizen such as the applicant 'with a serious criminal record that includes crimes of violence against his former partner and minor children should expect to lose his visa and forfeit the privilege of remaining in Australia' (at [87]);
(10)as to 'social discrimination and harm … because of his mental health condition', the applicant 'risks facing harm if returned to [his country of nationality] because of his mental health condition' - 'arguably even death given the consequences that flow from this mental disability if left untreated' (at [102]‑[104]); and
(11)the applicant's ties to the Australian community are that he has engaged in some employment and wants a relationship with his two children although it is unclear whether he would ever get some sort of court ordered access given his past behaviour; being matters outweighed by other considerations (at [110]).
Although the Tribunal found that there was a risk of harm to Mr Suleiman if he was returned to his country of nationality and that was a finding that weighed in favour of revoking the decision to cancel his visa, the Tribunal concluded that this 'secondary consideration' did not outweigh the Tribunal's findings in relation to 'primary considerations': at [105]-[106]. The same reasoning was applied to 'community ties': at [111], see also [132].
The application in this court
Mr Suleiman is self‑represented. The form of application filed seeks an extension of time and refers to an appeal mentioned in s 44(2A) of the Administrative Appeals Tribunal Act 1975 (Cth). An appeal of that kind would be a statutory appeal on a question of law. However, the grounds of the application allege various types of jurisdictional error and are couched in terms of a substantive application for relief in the original jurisdiction of this Court under the Migration Act.
A statutory appeal from the Tribunal on a question of law is not available in relation to a Tribunal decision on a migration matter: s 43C(c) of the Administrative Appeals Tribunal Act. Rather, the present application is in respect of a privative clause decision of the Tribunal under s 500 and is therefore in the original jurisdiction of this Court: s 476A(1)(b) of the Migration Act. The jurisdiction in such cases is the same as 'the High Court under paragraph 75(v) of the Constitution': s 476A(2). So, for present purposes, the applicant must demonstrate jurisdictional error.
Accordingly, the application is one in which an extension of time is sought and if an extension is granted then a review of the decision of the Tribunal is sought on the basis that there has been jurisdictional error.
Further, the decision under s 501CA was made by a delegate and was not a decision 'made personally by the Minister'. Therefore, it is not necessary to consider the effect upon the jurisdiction of this Court of the timing of the amendments to s 476 and s 476A concerning decisions under s 501CA made personally by the Minister: Whittaker v Minister for Immigration and Border Protection [2017] FCA 494 per Derrington J.
Extension of time
The delay in filing the application in this court was about seven days. An application was filed in error in the Federal Circuit Court within time. The Minister accepts that if there is merit in the application then it is appropriate for an extension of time to be granted. For reasons which follow there is merit in the application. Therefore, there should be an extension of time to enable the application to be heard.
The grounds
The application raises complaints expressed in very general terms. They are:
1.The Tribunal was in error by making a decision on my case which is not in a substantive sense fair; it is a denial of natural justice.
2.The Tribunal failed to assess whether legislation properly construed the obligation to accord natural justice.
3.The Tribunal did not assess/consider the real risk of significant harm to my person upon return to [place of nationality].
4.They relied on irrelevant factors and materials which have nothing to do with my persecution.
5.They ignored relevant materials. Identified the wrong Issue and asked themselves the wrong questions.
6.They made an incorrect interpretation and applied applicable law in a way that affects the exercise of power.
In the way they are expressed these grounds do not disclose any arguable ground of jurisdictional error due to the lack of any particulars to support each ground. Save for the matter addressed below, nothing emerged in the course of the hearing that exposed an arguable basis for review.
One ground raised was to the effect that the Tribunal did not properly interpret and apply the relevant provisions of the Migration Act. I indicated at a case management hearing that the Court would be assisted by submissions from the Minister concerning the approach required on review by the Tribunal where an applicant claims that personal harm will result if the applicant was to be returned to his or her place of nationality, including the related question of the effect of Direction 65.
In these reasons I deal first with the Tribunal's approach to the issue of harm if the applicant was to be returned to his place of nationality and I then give reasons for my view that the application otherwise raises no arguable claim of reviewable error on the part of the Tribunal.
The Tribunal's reasons as to the risk of harm
The Tribunal found correctly that it was required to comply with Direction 65: at [28]. It recorded the provisions of Direction 65 that identified the three 'primary considerations' that the Tribunal must take into account, namely (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: at [36].
The Tribunal also quoted the terms of para 14(1) of Direction 65 which state that in deciding whether to revoke the mandatory cancellation of a visa 'other considerations must be taken into account where relevant' and that those considerations include, but are not limited to, certain matters in a list which includes 'International non‑refoulement obligations': at [89]. The Tribunal referred to those other considerations as 'secondary considerations'.
The term secondary considerations is not used in Direction 65. Rather, it refers consistently to 'other considerations' which 'must be taken into account' (emphasis added).
As to the relative weight to be given to primary and other considerations, para 8 of Direction 65 (which was quoted by the Tribunal at [34]) provides:
(1)Decision-makers must take into account the primary and other considerations relevant to the individual case …
(2)In applying the considerations (both primary and other), information and evidence from independent and authoritative sources should be given appropriate weight.
(3)Both primary and other considerations may weigh in favour of, or against, refusal, cancellation of the visa, or whether or not to revoke a mandatory cancellation of the visa.
(4)Primary considerations should generally be given greater weight than the other considerations. [The Tribunal referred to 'more weight']
(5)One or more primary considerations may outweigh other primary considerations.
As to its finding that Mr Suleiman risked facing harm if returned to his country of nationality because of his mental condition, the Tribunal posed the question 'whether this finding in relation to what is an 'other' or secondary consideration outweighs the Tribunal's findings in relation to the primary considerations': at [105]. It concluded by noting that the primary considerations in Direction 65 'are normally given greater weight than the other considerations and in light of the evidence before it, the Tribunal finds that the primary considerations here clearly outweigh this secondary consideration': at [106].
The use of the term 'secondary'
The use by the Tribunal of the term 'secondary' indicates that the 'other considerations' are always of lesser importance. However, Direction 65 makes clear that an evaluation is required in each case as to the weight to be given to the 'other considerations' (including non‑refoulement obligations). It requires both primary and other considerations to be given 'appropriate weight'. Direction 65 does provide that, generally, primary considerations should be given greater weight. They are primary in the sense that absent some factor that takes the case out of that which pertains 'generally' they are to be given greater weight. However, Direction 65 does not require that the other considerations be treated as secondary in all cases. Nor does it provide that primary considerations are 'normally' given greater weight. Rather, Direction 65 concerns the appropriate weight to be given to both 'primary' and 'other considerations'. In effect, it requires an inquiry as to whether one or more of the other considerations should be treated as being a primary consideration or the consideration to be afforded greatest weight in the particular circumstances of the case because it is outside the circumstances that generally apply.
This is a different question to that posed by the Tribunal which was whether a finding as to a consideration which had been classified as a secondary consideration outweighed the primary considerations which were normally to be given greater weight.
The difficulty with the Tribunal's approach is the characterisation of the 'other' considerations as secondary. It was submitted by the Minister that: (a) the Tribunal had nevertheless weighed all considerations and it was a matter for the Tribunal as to the weight to be given to particular considerations; (b) there was no suggestion that considerations that the Tribunal was required to take into account had not been considered; and (c) it was not a case where the Tribunal had found that the considerations it had described as secondary considerations will always be outweighed by the primary considerations.
It is true that the Tribunal did not in terms state that secondary considerations could not be treated as having equal or greater importance in any particular case. However, equally it did not say that despite the description 'secondary considerations', they may be afforded equal or greater weight than primary considerations in an appropriate case. In my view, the use of the term 'secondary' conveys an interpretation of Direction 65 that establishes a hierarchy of considerations to be applied in all instances. It is a term that the Tribunal used in the heading before considering the other considerations: at [89]. It is also a term that it used when weighing the primary considerations and the other consideration of risk of harm if Mr Suleiman was returned to his country of nationality.
Counsel for the Minister relied upon the absence of the term 'secondary' when the Tribunal expressed its conclusion at [117]. However, the conclusion is, in effect, a summary of the earlier reasoning at [104]-[106] where that term is used.
To treat the other consideration as secondary irrespective of its character in the particular case does not conform to the language of Direction 65. So, in this case, even though the Tribunal found that the applicant was 'at risk of harm - arguably even death given the consequences that flow from this mental disability if left untreated' this was a matter that it placed as always being of lesser importance than the primary considerations. The Tribunal did not consider, as it was required to do by Direction 65, whether in the specific circumstances the non‑refoulement obligations should be afforded greater weight.
As I have noted, Direction 65 is given under s 499 of the Migration Act.
The task for the Tribunal (like the delegate of the Minister) was to form a state of satisfaction as to whether the person passed the 'character test' or 'there is another reason why the original decision should be revoked': s 501CA(4). The satisfaction referred to is a state of mind which must be formed reasonably and on a correct understanding of the law: Goundar v Minister for Immigration and Border Protection [2016] FCA 1203 at [54] (applying Gageler and Keane JJ in Wei v Minister for Immigration and Border Protection [2015] HCA 51; (2015) 257 CLR 22 at [33] and Graham v Minister for Immigration and Border Protection [2017] HCA 33 at [57]).
In order to validly exercise the review power entrusted to it under s 500(1)(ba), the Tribunal was required to make a decision guided by a correct understanding of Direction 65 which formed a constraint upon the statutory authority of the Tribunal as an administrative decision‑maker. In the particular circumstances, the Tribunal approached the matter on the basis that Direction 65 required it to consider matters raising non‑refoulement obligations as secondary considerations. For reasons I have given, that approach was not correct. As there was an incorrect understanding of the nature and extent of the statutory provisions conferring the relevant decision-making power there was jurisdictional error.
Also, for the following reasons, Direction 65 could not operate in a manner that would cause the 'body' entrusted with the making of a decision under s 501CA(4) in any particular case, to act inconsistently with the requirement of that provision as determined by a Full Court of this Court in BCR16 v Minister for Immigration and Border Protection [2017] FCAFC 96; (2017) 248 FCR 456.
The Tribunal's approach to the decision in BCR16
After referring to Direction 65 and noting that the applicant was entitled to apply for a protection visa, the Tribunal said at [93]:
Until recently, the Tribunal would have found that, because of his ability to apply for a Protection visa, the Tribunal was not required to assess any non‑refoulement obligations owed to [the applicant]. It was generally accepted that because Direction 65 specifically states that it is not necessary to determine a non‑refoulement issue in circumstances where an applicant can apply for a Protection visa, the Tribunal would normally rely on any non‑refoulement assessment being made by another body specifically charged with determining the validity of a Protection visa claim.
The Tribunal then stated '[t]hat position is now disputed' because of the recent decision of a Full Court of this Court in BCR16. The Tribunal stated that because of the decision in BCR16 it 'is required to assess any type of harm that might arise should [the applicant] be deported [to his place of nationality]': at [94] (original emphasis).
Three matters arise from the Tribunal's approach to Direction 65 and the decision in BCR16. First, it is apparent that but for the decision in BCR16 the Tribunal would have followed the terms of Direction 65 and would have concluded that it was unnecessary to determine the applicant's claims of harm if returned to his country of nationality because it was open to the applicant to advance those claims in an application for a protection visa. Second, the Tribunal considered that it was required by BCR16 to assess any type of harm that might arise should the applicant be deported to his country of nationality. Third, although it considered the risk of harm to the applicant, in the end it used the terms of Direction 65 to conclude that the risk of harm was a consideration of secondary importance and was outweighed by the primary considerations under Direction 65.
One aspect of the reasoning by the majority (Bromberg and Mortimer JJ) in BCR16 was the recognition that an application for a protection visa may be rejected without a consideration of non‑refoulement obligations, particularly on character grounds: at [36]-[46], [52]. This means that such matters would not necessarily be considered as part of dealing with an application for a protection visa.
A further aspect was a recognition of the 'qualitatively different exercise' that is undertaken in considering whether to grant a protection visa (s 65) compared to whether to revoke a decision to cancel a visa after receiving representations raising reasons why that should occur (s 501CA(4)): at [49].
In that context, the majority found that there was jurisdictional error when considering the exercise of the revocation power under s 501CA(4) in leaving any issue of harm raised by the applicant to be dealt with in the course of an available application for a protection visa. The majority in BCR16 found that the jurisdictional error was to be characterised as a denial of procedural fairness or a failure to carry out the task required under s 501CA(4): at [62]. The error was not a failure to take into account a mandatory relevant consideration: at [61].
These conclusions reflect a finding that in order for there to be a valid exercise of the statutory power under s 501CA(4), it is necessary to consider any risk of harm if the person was to be returned to his or her place of nationality (not just harm that would give rise to non‑refoulement obligations) where that risk has been raised by the person concerned.
There is no hierarchy of considerations expressed within the state of satisfaction required by s 501CA(4). Therefore, it would be contrary to s 501CA(4) to approach the matter on the basis that certain considerations were inherently less important in forming the state of satisfaction required by the Act.
However, in BCR16 the decision whether to exercise the power under s 501CA(4) was made by the Assistant Minister personally: at [13]-[16]. Although the description Assistant Minister is used, the official title is Parliamentary Secretary. The Assistant Minister (Parliamentary Secretary), unlike the Tribunal, was not bound by Direction 65: Bochenski v Minister for Immigration and Border Protection at [79] (Bromwich J, Bromberg and Charlesworth JJ agreeing). In BCR16, the Court did not consider how Direction 65 was to be approached where the decision was made by a body that was required to comply with Direction 65.
The statutory authority conferred upon the Minister by s 499 is, relevantly for present purposes, to give directions to the Tribunal as the body exercising the power under s 501CA(4). However, those directions must conform to the requirements of the Act: s 499(2). Further, directions under s 499 must be complied with: s 499(2A). They are not statements of policy of a kind where the decision-maker must always have in mind whether, in the particular circumstances, the policy should be departed from: see Re Becker; Ex parte Minister for Immigration and Ethnic Affairs (1977) 15 ALR 696 at 699. (Although, an instrument under s 499 may contain both directions and statements that do not more than offer 'guidance': Williams v Minister for Immigration and Border Protection [2014] FCA 674; (2014) 226 FCR 112 at [37]‑[43]).
Therefore, if a s 499 direction requires steps to be taken that are contrary to the Act, it is invalid.
Accordingly, the Tribunal correctly approached the matter on the basis that the decision in BCR16 meant that Direction 65 could not require the Tribunal to, in effect, ignore the matters raised by the applicant as to the risk of harm. The same would apply if Direction 65 required the Tribunal to treat any matter as a secondary consideration. Direction 65 could identify matters that were required to be considered in all case (namely, the primary considerations). However, it could not direct that a particular matter be given less weight in all cases. So, if I am wrong in the view that I have taken as to the meaning of Direction 65 and it required the 'other considerations' to be given less weight then that too was an aspect of the direction that could not validly have confined the Tribunal.
Other grounds of application
For the above reasons I uphold ground 6 of the application. Grounds 1 to 5 are without any particulars. The natural justice grounds, being grounds 1 to 3, are not supported by the evidence. The Tribunal afforded Mr Suleiman a hearing at which he was able to produce materials to support his application. The Tribunal had regard to that material and requested the Minister to produce further material pursuant to s 500(6K). The Tribunal member prepared detailed and careful reasons dealing with all matters raised.
As to grounds 4 and 5, they appear to raise complaints that the Tribunal failed to take into account considerations that it was required to take into account. Mr Suleiman plainly failed the character test as defined in the Migration Act. When his visa was cancelled he was serving a term of imprisonment and therefore s 501(3A)(b) was satisfied. The Tribunal fully considered all matters advanced to support the application and addressed each of the considerations in Direction 65.
It follows that there is no merit in these grounds.
Description of the applicant
In the proceedings before the Tribunal it was determined that it was appropriate to restrict the identification of the applicant and refrain from disclosing other names that might identify the applicant. The Tribunal did so, in part, because there were claims made of the risk of persecution on the basis of religious belief. Those claims were not upheld by the Tribunal and were not raised before this Court.
There is no statutory provision requiring restricted identification in these proceedings. Such a course would only be adopted by this Court if grounds for a suppression order as to the name of an applicant were established. The Minister was content for the identity of Mr Suleiman to not be disclosed in these proceedings. However, Mr Suleiman does not seek a suppression order. He says that his name can be stated as the applicant in this case. Further, the concerns found by the Tribunal as to the risk to the applicant if he was returned to his country of nationality arise from the lack of available mental health services and treatment, not the risk of persecution.
In considering whether to make a suppression or non‑publication order it is necessary to take into account that a primary objective of the administration of justice is to safeguard the public interest in open justice: s 37AE of the Federal Court of Australia Act. There is a high threshold for the making of an order: Chen v Migration Agents Registration Authority (No 1) [2016] FCA 649 at [11]‑[15].
In those circumstances, I see no basis for a suppression order in respect of the name of Mr Suleiman as the applicant in these proceedings. He should be named as the applicant.
Conclusion
The Tribunal found that there was a risk of harm to the applicant, a risk that arguably included death, yet treated that matter as a secondary consideration to be given less weight than the primary considerations in Direction 65. In doing so, the Tribunal acted upon an incorrect understanding of the law. It was either an incorrect interpretation of Direction 65 or a failure to approach the required statutory task of satisfaction as to whether there was any reason why the original decision should be revoked in the manner explained in BCR16. The error was jurisdictional because it concerned an attribute of the power entrusted to the Tribunal. The decision of the Tribunal should be set aside and the matter should be remitted to the Tribunal to be dealt with according to law. The Minister should pay any costs of Mr Suleiman associated with the substantive application for review.
I certify that the preceding fifty-two (52) numbered paragraphs are a true copy of the Reasons for Judgment herein of the Honourable Justice Colvin. Associate:
Dated: 2 May 2018
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