Irish subsidiary protection regulations requiring prior asylum refusal upheld as valid EU implementation method.
Legislator-Zusammenfassung
KI-generiertThe applicant sought judicial review to bypass the requirement of first applying for asylum before seeking subsidiary protection. The court found the regulations lawful and within the scope of the EU Qualification Directive, rejecting the claim that the procedural sequence was unlawful. Consequently, the applicant was not entitled to the requested orders to allow an independent application.
Legislator-Regeste
KI-generiertS.I. 518 of 2006; Council Directive 2004/83/EC: The State's choice to require an applicant for subsidiary protection to first seek asylum and be refused is a legitimate mode of implementation and does not render the regulations ultra vires.
Schlagwörter
KI-generiertZitierte Gesetzesbestimmungen
KI-generiertVerwandte Entscheide
KI-generiertVolltext
Neutral Citation Number: [2010] IEHC 489
THE HIGH COURT
JUDICIAL REVIEW
2009 1019 JR
BETWEEN
H. N.
APPLICANT
AND
THE MINISTER FOR JUSTICE, EQUALITY AND LAW REFORM,
IRELAND AND THE ATTORNEY GENERAL
RESPONDENTS
JUDGMENT OF MR JUSTICE RYAN, delivered on the 15th December 2010
1. EU Council Directive 2004/83/EC provides for applications for subsidiary protection for persons who are not entitled to refugee
status but who are nevertheless at risk of serious harm. The State implemented the Qualification Directive, as it is known, by S.I. 518
of 2006. These regulations provide that subsidiary protection may be sought by a person whose application for asylum has been
refused. They do not allow for an independent application so a person has to apply for asylum before seeking subsidiary protection.
2. The applicant wants to apply for subsidiary protection without going through the asylum process. He accepts that he is not a
refugee because he does not fear persecution for a Convention reason but he claims that he does qualify for subsidiary protection. If
he is obliged to claim refugee status before seeking what he believes he is really entitled to, he will be making a false claim and will or
may suffer prejudice. The applicant objects to this.
3. The applicant's case is that he should not have to go through this charade. He claims that the Irish regulations are in conflict with
the EU directive. He obtained leave to bring judicial review proceedings by order of this Court in the following terms:
1. The first named respondent has failed to consider the exercise of his discretion pursuant to Regulation 4(2) of the EC
(Eligibility for Protection) Regulations, 2006 (S.I. 518 of 2006) to accept the applicant’s application notwithstanding that
the applicant is not a failed asylum seeker;
2. Regulation 3(1) and Regulation 4(2) of the EC (Eligibility for Protection) Regulations, 2006 (S.I. 518 of 2006) are
unlawful and ultra vires the provisions of the European Communities Act, 1972 (No. 27 of 1972) and Council Directive
2004/38/EC insofar as and to the extent that they provide that the first named respondent is entitled to refuse to
consider the application for subsidiary protection of a person who is not a failed asylum seeker;
3. The applicant is not entitled to work unless his application for subsidiary protection is successfully determined. The
applicant will sustain loss and damage waiting for a futile application for asylum to be refused should he be obliged to
make such an application.
4. The applicant claims a declaration that Regulation 3(1) and Regulation 4(2) of the 2006 Regulations are unlawful and ultra vires the
European Communities Act, 1972 and the Qualification Directive. He is seeking orders of mandamus and certioari arising out of the
decision by the Minister to refuse to consider his application for subsidiary protection.
Facts
5. The applicant is a national of Pakistan. He entered the State pursuant to a student visa in 2003. He married an Irish national in
2004, and was granted permission to remain in the State until 2005. Following the break-down of his marriage, this permission was not
renewed. On 23 February 2006, the applicant was informed that the first respondent proposed to deport him. The applicant did not
make a claim for asylum at any time, however, on 10 July 2009 he applied for subsidiary protection under the European Communities
(Eligibility for Protection) Regulations, 2006. On 27 July 2009, the first respondent informed the applicant that only a person who has
been refused refugee status can apply for subsidiary protection.
E.C. (Eligibility for Protection) Regulations 2006
6. The purpose of the EC (Eligibility for Protection) Regulations, SI 518 of 2006 is to give effect to the Qualification Directive. The
relevant regulations are as follows.
Regulation 2 defines a person eligible for subsidiary protection as one
(a) who is not a national of a Member State,
(b) who does not qualify as a refugee,
(c) in respect of whom substantial grounds have been shown for believing that the person concerned, if returned to
this or her country of origin, would face a real risk of suffering harm as defined in these regulations.
Regulation 3(1) provides that:
Subject to paragraph (2), these Regulations apply to the following decisions (in these Regulations referred to as “protection
decisions”) made on or after the coming into operation of these Regulations:
(a) a recommendation under section 13(1) of the 1996 Act;
(b) an affirmation under paragraph (a) or a recommendation under paragraph (b) of section 16(2) of that Act;
(c) the notification of an intention to make a deportation order under section 3(3) of the 1999 Act in respect of a
person to whom subsection 2(f) of that section relates;
(d) a determination by the Minister under Regulation 4(4) or 4(5).
Regulation 4 (2) states:
The Minister shall not be obliged to consider an application for subsidiary protection from a person other than a person to whom
section 3(2)(f) of the 1999 Act applies or which is in a form other than that mentioned in paragraph (1)(b).
Section 3 of the Immigration Act, 1999, referred to in Regulation 4(2), states, intera alia:
(1) Subject to the provisions of section 5 (prohibition of refoulement) of the Refugee Act, 1996, and the subsequent
provisions of this section, the Minister may by order (in this Act referred to as “a deportation order”) require any non-
national specified in the order to leave the State within such period as may be specified in the order and to remain
thereafter out of the State.
(2) An order under subsection (1) may be made in respect of –
…
(f) a person whose application for asylum has been refused by the Minister
Submissions
7. The applicant submits that the EC (Eligibility for Protection) Regulations 2006 do not properly transpose the Qualification Directive
into Irish law as they prevent an application for subsidiary protection being made by a person who is not a failed asylum seeker. On
the facts of this case, the applicant submits he is not eligible for refugee status as he does not fear persecution on the grounds set
out in the Geneva Convention but he is, however, in need of international protection.
8. The applicant argued that the Qualification Directive does not limit subsidiary protection to failed asylum seekers. In support of
this, his counsel Mr O’Reilly SC cited Recitals 24, 25 and 26 of the Directive. Recital 24 states:
…Subsidiary protection should be complementary and additional to the refugee protection enshrined in the Geneva
Convention.
Recital 25 states:
It is necessary to introduce criteria on the basis of which applicants for international protection are to be recognised as
eligible for subsidiary protection. Those criteria should be drawn from international obligations under human rights
instruments and practices existing in Member States.
Recital 26 states:
Risks to which a population of a country or a section of the population is generally exposed do normally not create in
themselves an individual threat which would qualify as serious harm.
9. Counsel also relied on the travaux préparatoires of the Qualification Directive and, in particular, the Commission Proposal for the
Directive (O.J. C 51E, 26.2.2002), the Opinion of the Economic and Social Committee (O.J. C221, 17.9.2002) and a Report from the
Commission to the Parliament (COM (2010) 314, Brussels 16.6.2010). He argued that an objective of the Commission Proposal is to
prevent the abuse of asylum applications and requiring a person to apply for asylum in circumstances where he cannot qualify as a
refugee would breach this objective. The applicant further relied on the Proposal’s description of subsidiary protection as a
“supplementary status” and the definition of an application for international protection as a request by a third country national for
protection on the grounds that s/he is a refugee “or” a person in need of subsidiary protection.
10. Finally, the applicant cited European Court of Justice Case C-465/07 Elgafaji v Staatssecretarias Van Justitie [2009] ECR I – 921,
for the proposition that the criteria for subsidiary protection are wider than those that apply to the grant of refugee status. The
applicant submitted that as the criteria differ, an application for subsidiary protection can exist separately and apart from an
application for refugee status.
11. The respondent submitted that the Regulations conform to the Directive and the applicant is not entitled to apply for subsidiary
protection unless, intera alia, he has first failed to qualify as a refugee. In support of this argument, the respondent relied on Article
2(e) of the Directive, which states that:
[a] person eligible for subsidiary protection» means a third country national or a stateless person who does not qualify as
a refugee but in respect of whom substantial grounds have been shown for believing that the person concerned, if
returned to his or her country of origin, or in the case of a stateless person, to his or her country of former habitual
residence, would face a real risk of suffering serious harm as defined in Article 15, and to whom Article 17(1) and (2) do
not apply, and is unable, or, owing to such risk, unwilling to avail himself or herself of the protection of that country
The respondent submitted that the key phrase of Article 2(e) is a “person who does not qualify as a refugee”. This phrase has a
community meaning and should be read in conjunction with variations of the phrase in Articles 4, 23, 25 and 32 of the Procedures
Directive (Council Directive 2005/85/EC), such that the question of ‘qualification’ is to be determined after an examination by a
competent authority and is not to be determined by an individual applicant of his own accord. The respondent argued that Article 5.2
of the Commission Proposal had contained a ‘stand-alone’ right to apply for subsidiary protection independent of an application for
asylum but it was removed in the final adopted version of the Directive. This was confirmation that the Directive was not intended to
include such a right.
12. Finally, the respondent cited Izevbekhai v Minister for Justice Equality and Law Reform (Unreported, Supreme Court, 9 July 2010)
where Fennelly J. stated that Regulation 4(2) of the 2006 Regulations has the effect that “the Minister is not obliged to consider an
application for subsidiary protection from any person other than one to whom that provision applies.” It was submitted therefore, that
the respondent has no discretion to accept an application from the applicant in circumstances where he is not a person whose
application for asylum has been refused by the Minister.
Analysis
13. The debate in this case is essentially a theoretical one. The applicant is free to apply for subsidiary protection; the only question
is whether he makes that in the first instance or whether he has to go through the process of applying for asylum and being refused
before he makes his case for subsidiary protection. Whichever interpretation of the debate is correct, the applicant is in a position to
make a case for subsidiary protection. In these circumstances, it is questionable whether it is legitimate to use judicial review for the
purpose of establishing who is correct in an exegetical debate about the E.U. Directive.
14. As to the issue in contention, it seems to me that, while there is something to be said for each side, the respondents’ argument is
more correct. Both sides are in agreement that there is a choice of the mode of implementation of the Directive. If the option chosen
by the State is among the legitimate ways of implementing it, the applicant cannot succeed. He would have to show that the choice
made by the State was not permitted by the Directive or that the Regulations failed to do something that the Directive mandated. If
the furthest the applicant can put the case is that the Directive permits a different way of doing it, that is not enough. Indeed, it is
not sufficient for him to show that the Directive envisages a different way of doing it. Unless he establishes that the mode adopted
by the Regulations is not in accordance with the Directive, either by doing something in a way that the Directive does not permit or
by failing to do something that the Directive requires, he cannot succeed. On this issue, my view is that the Regulations have
adopted a mode of implementing the Directive that is legitimately within its terms and consistent with its meaning. It may not be the
only way but that does not invalidate it. The fact that the Commission’s original proposal for an independent application was not
adopted reinforces this interpretation.
15. Whatever view one takes about the debate, the worst prejudice that can be claimed by the applicant to arise out of the alleged
misapplication of the Directive by the State is that he has got to apply first for asylum before moving on to his real case, as he says,
which is subsidiary protection. He says that this means he is making a false application or an untruthful application or even a
fraudulent application. I think this apprehension is unfounded. There is nothing to stop him accompanying his application with a letter
from his solicitor setting out the true position as he maintains; there is nothing to stop him giving evidence in accordance with the
truth as he knows it; there is nothing to stop him making it quite clear that he is proceeding in this way because it is the required and
only means by which he can make his real case.
16. My conclusion accordingly is that the applicant is not entitled to the orders sought by way of judicial review.