Thaworn (Migration)

Thaworn (Migration) [2020] AATA 6188 (7 August 2020)
DECISION RECORD
DIVISION:Migration & Refugee Division
APPLICANT:  Ms Supaporn Thaworn
CASE NUMBER:  1933668
DIBP REFERENCE(S):  BCC2018/1373029
MEMBER:Ann Duffield
DATE:7 August 2020
PLACE OF DECISION:  Brisbane
DECISION:The Tribunal affirms the decision not to grant the applicant a Partner (Residence) (Class BS) visa

Statement made on 7 August 2020 at 10.35am

CATCHWORDS
MIGRATION – Partner (Residence) (Class BS) visa – Subclass 801 (Partner) – relationship ceased – family violence claim – non-judicially determined claim – evidential requirements not met – decision under review affirmed
LEGISLATION
Migration Act 1958 (Cth), s 65
Migration Regulations 1994 (Cth), rr 1.21, 1.23, 1.24, 1.25; Schedule 2, cl 801.221

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 8 November 2019 to refuse to grant the applicant a Partner (Residence) (Class BS) visa under s.65 of the Migration Act 1958 (the Act).
The applicant applied for the visa on 23 March 2018 on the basis of her relationship with her sponsor. At that time, Class BS contained Subclass 801. The criteria for the grant of this visa are set out in Part 801 of Schedule 2 to the Migration Regulations 1994 (the Regulations).
The primary criteria must be satisfied by at least one applicant. Other members of the family unit, if any, who are applicants for the visa need satisfy only the secondary criteria. Relevantly to this matter the primary criteria include cl.801.221 which requires the applicant to be the spouse or de facto partner of the sponsor, unless the relationship has ceased and certain circumstances exist. These include that the applicant, or a member of the family unit, has suffered family violence committed by the sponsor: cl.801.221(6)(b), (c)(i). The applicant claims this occurred in this case.
The delegate refused to grant the visa on the basis that the applicant did not meet cl.801.221 because the applicant is no longer the spouse of the sponsoring partner and the applicant was unable to provide the evidentiary requirements to support a claim of family or domestic violence as the reason the relationship ceased.
The applicant appeared before the Tribunal via teleconference on 10 June 2020 to give evidence and present arguments. The Tribunal also received oral evidence from the applicant’s representative.
The applicant was represented in relation to the review by her registered migration agent.
For the following reasons, the Tribunal has concluded that decision under review should be affirmed.
BACKGROUND
The applicant provided the Tribunal with a copy of the delegate’s decision along with the application for review.
The applicant is a citizen of Thailand and first came to Australia in 2020 on a visitor visa. She returned to Australia in 2015 on another visitor visa and at that time met the sponsoring spouse. She departed and returned in 2016 on a 2-year student visa and she and the sponsoring spouse dated during that period. The applicant stating that she earned money to pay of her student debt and helped her family in Thailand.
The parties claimed to have first met on 15 November 2015 in Darwin and were married on 19 February 2018. The applicant claims that her sponsoring spouse moved into the applicant’s grandmother’s residence after their marriage.
The parties lodged an application for a subclass 820/801 visa on 23 March 2018. The applicant was granted a bridging visa in relation to that application on 23 March 2018 however before her visa application was decided, the department received advice from the applicant through her adviser on 22 November 2018 that the relationship with her sponsoring spouse had ceased as a result of family violence.
The applicant claims that after the marriage her husband’s attitude towards her changed and he was abusive and forced to her to have sex with him. She claims that she is cared that he will steal or damage the car and never pays for food and drink and has not financially supported her after the marriage. She claims that they live free of charge at the applicant’s grandmother’s residence and paid half of the power and water. On 21 June 2018 she sent him a text ending the marriage.
On 31 May 2019 the department wrote to the applicant requesting evidence of the alleged family violence in accordance with the regulations. She was also provided with details of the type of evidence deemed acceptable. On 25 June 2019 the applicant through her representative requested an extension of time to provide the requested documentation however there was no further response. On 12 August 2019 the department wrote to the applicant again requesting the required evidence, but none was forthcoming. The department made contact with the applicant’s nominated representative on 1 November 2019 in relation to the outstanding documents. However that representative ended her appointment through the provision of Form 956 which the applicant signed.
On 4 November 2019 the department sent the applicant an email at her nominated email address requesting that she make urgent contact with the department. The applicant has not responded to any of these contacts made by the department.
The Tribunal wrote to the applicant on 15 April 2020 inviting her to comment on or respond to information and to invite her to provide relevant information in relation to her claims. The applicant through her representative responded on the due date with the following statement:
Ms. Supaporn Thaworn has advised us in writing that she is unable to provide any of the prescribed forms of either judicial evidence or documentation to support a non-judicially determined claim of family violence.
The Tribunal wrote to the applicant on 22 May 2020 inviting her to attend a hearing on 10 June 2020. On 1 June 2020 the applicant’s representative sought an adjournment of the hearing scheduled for 10 June 2020 as the applicant was finding it difficult to obtain the relevant documents. The representative also requested that the matter be heard face to face in Darwin. The Tribunal formed a view that the applicant has been given ample opportunity to provide the evidence requested, after first having been unwilling or unable to provide any information at all, the request was refused.
On 5 June 2020 the Tribunal received a lengthy submission from the applicant’s representative seeking adjournment until a face to face hearing could be conducted. The submission included arguments suggesting that the Tribunal was required to offer a face to face hearing, a submission the Tribunal rejects, and that it would be unfair to proceed as matters of credibility would be considered.
The Tribunal wrote to the applicant through her representative refusing the request indicating that the hearing would deal largely with matters of fact, specifically, whether or not the applicant could provide the evidentiary requirements needed to support her claim of domestic or family violence.
The Tribunal received some submissions from the applicant indicating that the applicant wished to join her sister-in-law and grandmother as victims of family violence along with herself.
The relevant law at cl 820.221(3) states that an applicant an meet the requirements if the relationship between the applicant and the sponsoring partner has ceased and (a) the applicant; or (b) a dependent child of the sponsoring partner or of the applicant or of both of them; has suffered family violence committed by the sponsoring partner.
The Tribunal notes that the meaning of relevant family violence given by sub-regulations in 1.23(8) and (9) means conduct, whether actual or threatened, towards (a) the alleged victim; or (b) a member of the family unit of the alleged victim; that causes the alleged victim to reasonably fear, for, or to be reasonably apprehensive about, his or her own wellbeing or safety. Regulation 1.23 (9) states, however, for these Regulations an application for a visa is taken to include a non-judicially determined claim of family violence if: a) the applicant seeks to satisfy a prescribed criterion that the applicant, or another person mentioned in the criterion has suffered family violence; and (b) the alleged victim is (i) a spouse or de facto partner of the alleged perpetrator; or (ii) a dependent child of: (A) the alleged perpetrator; or (B) the spouse or de facto partner of the alleged perpetrator and his or her spouse or de facto partner; or (iii) a member of the family unit of a spouse or de facto partner of the alleged perpetrator (being a member of the family unit who has made a combined application for a visa with the spouse or de facto partner).
A person prescribed by the legislation in relation to whom can provide the relevant evidence includes the following:
a.A registered medical practitioner performing the duties of a medical practitioner;
b.A registered nurse performing the duties of a registered nurse;
c.A police officer of a state or territory;
d.A police officer of the Australian federal police
e.A witness statement that is made by someone other than the alleged victim to a police officer during the course of a police investigation;
f.An officer of a child welfare authority or a child protection authority;
g.A report made by a women’s refuge or family/domestic violence crisis centre;
h.A member of the Australian Association of Social Workers or a person who is eligible to be a member of that Association who has provided counselling or assistance to the alleged victim while performing the duties of a social worker.
i.A registered psychologist who has treated the alleged victim while performing the duties of a psychologist
j.A family consultant appointed under the family Law Act or a family relationship counsellor who works at a Family Relationship Centre listed on the Australian Government Family Relationship website
Neither the applicant’s sister-in-law or grandmother are included as applicants on the visa application or review application and hence have no standing in this matter. The Tribunal notes that they have both also provided statutory declarations in relation to family violence allegedly perpetrated against them by the applicant’s ex-husband. Again, they have no standing to provide such evidence, either as family members or individuals. In the former case, they are not applicants to the review and in relation to the second matter they are not included in the list of the types of persons competent to provide the relevant evidence. The Tribunal has, however, taken into account their statements.
CONSIDERATION OF CLAIMS AND EVIDENCE
In the present case, the applicant claims the relationship with the visa sponsor has ceased, and she has been the victim of family violence.
The Tribunal has considered whether the applicant and the sponsoring spouse were in a genuine, ongoing and exclusive spousal relationship, as envisaged by the Migration Act at the time that the alleged family violence occurred.
At the Tribunal hearing the Tribunal put to the applicant that there was little evidence of their relationship on the department’s file noting that in their application she and the sponsor had stated that they could not provide the required evidence as they had been victims of a recent cyclone in Darwin and had difficulty obtaining the evidence. The Tribunal noted that there was a letter to the sponsor’s employer requesting that his pay be deposited into an account jointly held with the applicant and a letter from Toyota congratulating them on the purchase of the vehicle. The applicant told the Tribunal that she had provided additional information to her agent. The Tribunal told the applicant that she could take two weeks to obtain whatever evidence she wanted the Tribunal to consider putting to her that unless it could be satisfied that a genuine spousal relationship existed at the time of the claimed violence, it could affirm the decision under review without looking at the domestic violence matters.
The applicant undertook to provide the additional information and sent the Tribunal a number of documents which have been taken into account and discussed, where relevant, below.
Did a genuine relationship exist at the time of the alleged family violence?
The Tribunal has considered the evidence of the couple’s relationship including the following documents:
a.A form 888 from Hudsaya Yogl dated 23 March 2018 attesting to the genuine relationship between the applicant and the sponsor.
b.A form 888 from Warunee Brinkley dated 22 June 2020 stating that the couple were in a genuine and loving relationship.
c.A detailed statement of the couple’s relationship
d.Some photographs of the couple together and with others including the sponsor’s daughter
e.Screen shots of hundreds of text messages between the applicant and the sponsor
f.Copies of bank statements from March 2018 and some household and utility bills
g.A statutory declaration from the applicant
For the purposes of this review, the Tribunal accepts that the applicant and the sponsor were in a partner relationship and that this relationship has ceased. The issue that arises on the evidence in this case is whether the applicant has suffered family violence committed by the sponsor, within the meaning of the Regulations.
Under r.1.23 of the Regulations, a person is taken to have suffered or committed family violence if there is evidence tested before a court; or the visa application includes a non-judicially determined claim of family violence, and either the Minister (or the Tribunal on review) is satisfied that the alleged victim has suffered relevant family violence or an opinion of an independent expert has been given that the alleged victim has suffered relevant family violence. Relevant family violence is defined in r.1.21. These regulations, as relevant to this decision, are extracted in the attachment to this decision. The Tribunal notes that the violence, or part of the violence must have occurred during the relationship: r.1.23(3), (5), (7), (12), (14).
In the present case the applicant is seeking establish family violence on the basis of a non-judicially determined claim of family violence.
Has a claim of family violence been made under the regulations?
Under r.1.23, a visa application is taken to include a non-judicially determined claim of family violence where either a joint undertaking to a court has been made by the alleged victim and alleged perpetrator or evidence in accordance with r.1.24 is provided.
The applicant in this case is seeking to rely on evidence referred to in r.1.24 – namely, a statutory declaration under r.1.25 and evidence of a type and number specified by the Minister for these purposes.
A statutory declaration under r.1.25 must be made by the spouse or partner of the alleged perpetrator. If the alleged victim is the spouse or partner, the statutory declaration must set out the allegation of family violence, name the person alleged to have committed the relevant family violence and if the conduct was not directed at the spouse or partner, name the person to whom it is directed and their relationship with the deponent: r.1.25(2). There are different requirements if the family violence is alleged to have occurred to another person: r.1.25(3).
The applicant has provided the following pieces of evidence to support her claim:
a.A Form 1040 signed by Ms Saranya Boonma – a sister in law of the applicant who calls herself a student. For the reasons set out in paragraphs 18-22 the Tribunal does not accept this as meeting the evidentiary requirements.
b.A Form 1040 signed by Malaiporn Laosapar dated 9 June 2020 – an Auntie of the applicant who claims she is a housewife and business owner. For the reasons set out in paragraphs 18-22 the tribunal does not accept this as meeting the evidentiary requirements.
c.A Form 1040 signed by Nual Thaworn – the applicant’s grandmother who calls herself a housewife. For the reasons set out in paragraphs 18-22 the tribunal does not accept this as meeting the evidentiary requirements.
d.A Form 1040 signed by the applicant setting out the details of the alleged family violence perpetrated by the sponsoring spouse and naming him.
e.A Form 1040 signed by Ms Helen Stathis, a psychologist. Ms Stathis has provided evidence of her position. She claims to have met with the applicant on two occasions on June 3 and June 4 2020, just one week before the Tribunal hearing. Ms Stathis states that the applicant along with her family members have been the victims of family violence by the sponsoring spouse. She details heavy drinking on the part of the sponsoring spouse, who exhibited controlling and manipulative behaviours, emotional abuse, continual harassment, jealousy, yelling and swearing, accusations of the applicant being with other men, banging on her door, threatening to send her back to her country and financial abuse.
f.A form 888 from Vodkham Chutjma dated 22 June 2020 stating that the couple are loving and kind to each other and are in a genuine loving relationship and “are perfect match for each other”.
g.A Section 9(1) notice against the sponsor evicting him from the applicant’s home
h.A letter from Bowen Lawyers dated 1 November 2018 setting out the applicant’s claims but not offering an opinion as to whether or not the applicant suffered family violence.
i.A “Domestic Violence Warning Letter” from the Domestic Violence Legal Service dated 19 December 2018 to the sponsor warning him that the actions perpetrated by him against the applicant constitute domestic violence.
j.A number of abusive text exchanges between the applicant and the sponsor
The Tribunal has assessed the documents and also particularised its concerns about the evidence for the applicant to comment upon. The applicant did not provide any relevant comments and the Tribunal makes the following findings.
It is not clear to the Tribunal that Ms Stathis was performing any therapeutic role or performing her duties as a psychologist on the two occasions, some years after the event, and immediately prior to the Tribunal hearing, that she met with the applicant one day apart. It appears to the Tribunal that her opinion was made solely and specifically for the purpose of providing it to the Tribunal. For these reasons the Tribunal does not accept that Ms Stathis’ statement meets the evidentiary requirements of the Migration Act and Regulations.
A Form 1040 signed by Mr Gregory Goodluck, a registered Social worker. Mr Goodluck recounts the applicant’s statement to him that the sponsoring spouse threatened to send her back to her country if she didn’t sleep with him, verbal abuse, degrading and other comments in front of family and his refusal to leave the family home. Mr Goodluck states that in his opinion the applicant has suffered domestic violence at the hands of the perpetrator.
However, Mr Goodluck does not indicate the circumstances in which he was requested to complete the document, nor on how many occasions, when and in what context he met with the applicant to receive her account of events. There is no suggestion that Mr Goodluck provided counselling or assistance to the applicant whilst performing the duties of a social worker. For these reasons the Tribunal does not accept that Mr Goodluck’s statement meets the evidentiary requirements.
The letter from the Domestic Violence Legal Service names the perpetrator, details the violence and is made by a prescribed person on their letterhead. However it does not offer an opinion by the writer that the applicant suffered family or domestic violence. . For these reasons the Tribunal does not accept that Mr Goodluck’s statement meets the evidentiary requirements.

Letter from Bowen Lawyers sets out the claims made by the applicant but does not offer an opinion that the applicant suffered the relevant domestic violence.
The other Form 1040 documents are not made by prescribed persons and the Tribunal does not accept them as meeting the evidentiary requirements.
The Tribunal sent the applicant, through her representative a long and detailed letter setting out its concerns and assessment of the evidence she provided to support her claims after the scheduled hearing. The applicant was informed that the Tribunal had not yet formed a view and sought her comments on the information provided. A copy of that letter is attached.
Relevantly, in relation to the Tribunals detailed and specific concerns about the documents provided by the applicant to support her domestic violence claims, the applicant has again been unwilling or unable to provide the relevant documentation stating instead that she has “noted the Tribunal’s observations on the perceived deficiencies in the material…..and will seeking to obtain updated material from these two medical professionals”.
The Tribunal notes that the updated material has not been provided and no indication given as to when it might be provided. In any case, the Tribunal would have concerns about the extent to which the applicant or her adviser may direct those professionals in the giving of evidence.
The applicant, through her representative also sought an additional video hearing stating that the Tribunal was required, under section 360 of the Act to provide the applicant with such a hearing and objecting to the Tribunal putting to her information that called into doubt the existence of a genuine continuing and exclusive partner relationship prior to the alleged domestic violence. The Tribunal put this information to the applicant for the sake of providing completeness in its thinking and gave her an opportunity to respond to those particularised concerns, as it is required to do standing in the shoes of the decision-maker. She was put on notice that it was a concern and given an opportunity to comment. The tribunal does not accept that in doing so it has not been compliant in both the letter and the meaning of section 360.
Be that as it may, the Tribunal accepts, for the purposes of this decision that the applicant was in a relationship at the relevant time, it has simply gone on to assess the documents provided to support her domestic violence claims.
As these matters are factual in nature, and the applicant has been given several opportunities over a significant period to provide those documents, the Tribunal does not accept the applicant’s submission that a further oral hearing be necessary.
The Tribunal has afforded the applicant abundant procedural fairness in asking for the information and providing not only its assessment of the documents and evidence provided, but ample time to provide that information.
The applicant at the first request indicated that she was unable to provide the relevant documents and has now indicated that she is unwilling to provide comments on the Tribunal’s assessment of the documents eventually provided.
Therefore, the evidence presented does not meet the requirements of r.1.24. As such, a non-judicially determined claim of family violence has not been made under r.1.23.
CONCLUSION
Given the above conclusion that the claim of family violence has not been established, the applicant does not meet the requirements of cl.801.221(6)(b) and (c) for the grant of the visa. There is no evidence before the Tribunal that the applicant meets any of the alternative sub criteria. As the applicant does not meet an essential criterion for the visa, the Tribunal must affirm the decision under review.
DECISION
The Tribunal affirms the decision not to grant the applicant a Partner (Residence) (Class BS) visa
Ann Duffield
Senior Member

ATTACHMENT – EXTRACTS FROM THE MIGRATION REGULATIONS 1994
1.21 Interpretation
In this Division:
independent expert means a person who:
(a)is suitably qualified to make independent assessments of non-judicially determined claims of family violence; and
(b)is employed by, or contracted to provide services to, an organisation that is specified, in a legislative instrument made by the Minister, for the purpose of making independent assessments of non-judicially determined claims of family violence.
non-judicially determined claim of family violence has the meaning given by subregulations 1.23(8) and (9).
relevant family violence means conduct, whether actual or threatened, towards:
(a)the alleged victim; or
(b)a member of the family unit of the alleged victim; or
(c)a member of the family unit of the alleged perpetrator; or
(d)the property of the alleged victim; or
(e)the property of a member of the family unit of the alleged victim; or
(f)the property of a member of the family unit of the alleged perpetrator;
that causes the alleged victim to reasonably fear for, or to be reasonably apprehensive about, his or her own wellbeing or safety.
statutory declaration means a statutory declaration under the Statutory Declarations Act 1959.
violence includes a threat of violence.
…
1.23     When is a person taken to have suffered or committed family violence?
(1)For these Regulations, this regulation explains when:
(a)a person (the alleged victim) is taken to have suffered family violence; and
(b)another person (the alleged perpetrator) is taken to have committed family violence in relation to the alleged victim.
Note Schedule 2 sets out which visas may be granted on the basis of a person having suffered family violence. The criteria to be satisfied for the visa to be granted set out which persons may be taken to have suffered family violence, and how those persons are related to the spouse or de facto partner of the alleged perpetrator mentioned in this regulation.
Circumstances in which family violence is suffered and committed — injunction under Family Law Act 1975
(2)The alleged victim is taken to have suffered family violence, and the alleged perpetrator is taken to have committed family violence, if, on the application of the alleged victim, a court has granted an injunction under paragraph 114(1)(a), (b) or (c) of the Family Law Act 1975 against the alleged perpetrator.
(3)For subregulation (2), the violence, or part of the violence, that led to the granting of the injunction must have occurred while the married relationship between the alleged perpetrator and the spouse of the alleged perpetrator existed.
Circumstances in which family violence is suffered and committed — court order
(4)The alleged victim is taken to have suffered family violence, and the alleged perpetrator is taken to have committed family violence, if:
(a)a court has made an order under a law of a State or Territory against the alleged perpetrator for the protection of the alleged victim from violence; and
(b)[…] order was made after the court had given the alleged perpetrator an opportunity to be heard, or otherwise to make submissions to the court, in relation to the matter.
(5)For subregulation (4), the violence, or part of the violence, that led to the granting of the order must have occurred while the married relationship or de facto relationship existed between the alleged perpetrator and the spouse or de facto partner of the alleged perpetrator.
Circumstances in which family violence is suffered and committed — conviction
(6)The alleged victim is taken to have suffered family violence, and the alleged perpetrator is taken to have committed family violence, if a court has:
(a)convicted the alleged perpetrator of an offence of violence against the alleged victim; or
(b)recorded a finding of guilt against the alleged perpetrator in respect of an offence of violence against the alleged victim.
(7)For subregulation (6), the violence, or part of the violence, that led to the conviction or recording of a finding of guilt must have occurred while the married relationship or de facto relationship existed between the alleged perpetrator and the spouse or de facto partner of the alleged perpetrator.
Circumstances in which family violence is suffered and committed — non-judicially determined claim of family violence
(8)For these Regulations, an application for a visa is taken to include a non-judicially determined claim of family violence if:
(a)the applicant seeks to satisfy a prescribed criterion that the applicant, or another person mentioned in the criterion, has suffered family violence; and
(b)the alleged victim and the alleged perpetrator have made a joint undertaking to a court in relation to proceedings in which an allegation is before the court that the alleged perpetrator has committed an act of violence against the alleged victim.
(9)For these Regulations, an application for a visa is taken to include a non-judicially determined claim of family violence if:
(a)the applicant seeks to satisfy a prescribed criterion that the applicant, or another person mentioned in the criterion, has suffered family violence; and
(b)the alleged victim is:
(i)       a spouse or de facto partner of the alleged perpetrator; or
(ii)      a dependent child of:
(A)the alleged perpetrator; or
(B)the spouse or de facto partner of the alleged perpetrator; or
(C)both the alleged perpetrator and his or her spouse or de facto partner; or
(iii)     a member of the family unit of a spouse or de facto partner of the alleged perpetrator (being a member of the family unit who has made a combined application for a visa with the spouse or de facto partner); and
(c)the alleged victim or another person on the alleged victim’s behalf has presented evidence in accordance with regulation 1.24 that:
(i)       the alleged victim has suffered relevant family violence; and
(ii)      the alleged perpetrator committed that relevant family violence.
(10)If an application for a visa includes a non-judicially determined claim of family violence:
(a)the Minister must consider whether the alleged victim has suffered relevant family violence; and
(b)if the Minister is satisfied that the alleged victim has suffered the relevant family violence, the Minister must consider the application on that basis; and
(c)if the Minister is not satisfied that the alleged victim has suffered the relevant family violence:
(i)       the Minister must seek the opinion of an independent expert about whether the alleged victim has suffered the relevant family violence; and
(ii)      the Minister must take an independent expert’s opinion on the matter to be correct for the purposes of deciding whether the alleged victim satisfies a prescribed criterion for a visa that requires the applicant for the visa, or another person mentioned in the criterion, to have suffered family violence.
(11)The alleged victim is taken to have suffered family violence, and the alleged perpetrator is taken to have committed family violence, if:
(a)an application for a visa includes a non-judicially determined claim of family violence; and
(b)the Minister is satisfied under paragraph (10)(b) that the alleged victim has suffered relevant family violence.
(12)For subregulation (11), the Minister must be satisfied that the relevant family violence, or part of the relevant family violence, occurred while the married relationship or de facto relationship existed between the alleged perpetrator and the spouse or de facto partner of the alleged perpetrator.
(13)The alleged victim is taken to have suffered family violence, and the alleged perpetrator is taken to have committed family violence, if:
(a)an application for a visa includes a non-judicially determined claim of family violence; and
(b)the Minister is required by subparagraph (10)(c)(ii) to take as correct an opinion of an independent expert that the alleged victim has suffered relevant family violence.
(14)For subregulation (13), the violence, or part of the violence, that led to the independent expert having the opinion that the alleged victim has suffered relevant family violence must have occurred while the married relationship or de facto relationship existed between the alleged perpetrator and the spouse or de facto partner of the alleged perpetrator.

[2020] AATA 6188

Key Legal Topics

Areas of Law

Immigration

Administrative Law

Legal Concepts

Judicial Review

Standing

Procedural Fairness