SZTZT v Minister for Immigration

In this matter before Lloyd-Jones J of the Federal Court of Australia, the applicant sought judicial review of a decision made by the Migration Review Tribunal. The central dispute concerned the applicant's assertion that the Tribunal's published decision on its website contained references that jeopardised his safety, despite redactions.

The primary legal issue before the Court was whether the Tribunal's publication of its decision on the internet, even with some redactions, constituted an error of law. The applicant contended that the remaining references posed a risk to his safety.

Lloyd-Jones J reasoned that the applicant's submission regarding the published decision asked the Court to extend its review function beyond its proper scope. His Honour noted the Tribunal's stated policy for requesting the removal or editing of published decisions if their publication causes concern or is not in the public interest. The Court referred to the principle articulated by Kirby J in *Minister for Immigration and Ethnic Affairs v Wu Shan Liang & Ors* (1996) 185 CLR 259, that decisions must be read as a whole and considered fairly, rather than being subjected to a narrow, word-by-word scrutiny for minor slips. Applying this principle, his Honour found no error of law on the face of the Tribunal's decision when read in its entirety.

Consequently, the application was dismissed, and the applicant was ordered to pay the Minister's costs.