AHM18 v Minister for Home Affairs [2019] FCA 409

AHM18 v Minister for Home Affairs [2019] FCA 409

The return of the appellant to Najaf, his home city, does not constitute 'relocation' under s 36(2B)(a) of the Migration Act 1958. The Authority was not required to consider the reasonableness of relocation as no relocation was involved. There was no real risk of significant harm in Najaf, and therefore the appeal must be dismissed.

Jurisdiction
Australia
Judgment Date
26 March 2019
Procedural Posture
Appeal From Federal Circuit Court Decision / Judgment on Appeal
Outcome
Appeal dismissed
Legal Topics
['protection Visa' 'complementary Protection' 'internal Relocation Principle' 'judicial Review']

Case Brief

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Procedural Posture

Appeal From Federal Circuit Court Decision / Judgment on Appeal

  1. 1 ["Whether the Immigration Assessment Authority erred in not considering the reasonableness of the appellant's return to his hometown under s 36(2B)(a) of the Migration Act 1958" 'Whether the Authority misapplied s 36(2)(aa) and s 36(2B) of the Migration Act 1958' "Whether the appellant's return to Najaf constitutes 'relocation' triggering the relocation principle"]

Ratio Decidendi

The return of the appellant to Najaf, his home city, does not constitute 'relocation' under s 36(2B)(a) of the Migration Act 1958. The Authority was not required to consider the reasonableness of relocation as no relocation was involved. There was no real risk of significant harm in Najaf, and therefore the appeal must be dismissed.

Court Disposition

Appeal dismissed

Orders

  • ['The appeal be dismissed.' "The appellant pay the first respondent's costs of the appeal, to be assessed in default of agreement."]