High Court refuses leave to quash s.13 report where appeal process is inadequate to cure material illegality.
Sintesi Legislator
Generato dall'IAThe High Court refused leave to apply for judicial review to quash a Section 13 report by the Refugee Commissioner. The applicant argued the report was flawed and that the subsequent appeal process would not adequately address the alleged errors or provide a necessary oral hearing. The court held that intervention is only permitted in rare cases where the statutory appeal is unsuitable to cure a material illegality, which was not demonstrated here.
Regesto Legislator
Generato dall'IAs. 13 of the Refugee Act 1996; It is settled law that the High Court should intervene to review a section 13 report in advance of a Tribunal appeal only in rare and exceptional circumstances where it is necessary to rectify a material illegality incapable of cure by the appeal.
Parole chiave
Generato dall'IADisposizioni normative citate
Generato dall'IAGiurisprudenza citata
Generato dall'IATesto completo
Neutral Citation Number: [2009] IEHC 450
THE HIGH COURT
2008 307 JR
BETWEEN/
O. S. (A MINOR SUING BY HER FATHER AND NEXT FRIEND Z. S.)
APPLICANT
AND
REFUGEE APPLICATIONS COMMISSIONER, REFUGEE APPEALS TRIBUNAL, MINISTER FOR JUSTICE, EQUALITY AND LAW
REFORM, ATTORNEY GENERAL AND IRELAND
RESPONDENTS
JUDGMENT of Mr Justice Cooke delivered on the 14th day of October, 2009
1. This is a further case in which leave is sought to apply to quash, by certiorari, a report under s.13 of the Refugee Act
of 1996 by the Refugee Commissioner in circumstances where an appeal has been initiated but left in abeyance pending
the outcome of this proceeding.
2. In a number of judgments delivered in recent months the High Court has reviewed the case law on the issue as to the
attackability of a s. 13 report in those circumstances. In the light of the Kayode judgment the Supreme Court, earlier this
year, in one of the more recent cases I endeavoured very briefly to state the criteria indicated by that case law in the
following terms:-
“It is now settled law that consistently with the scheme and legislative intention of the 1996 Act this Court should
intervene to review a section 13 report and recommendation in advance of a decision on appeal by the Refugee
Applications Tribunal only in the rare and exceptional circumstances where it is necessary to do so in order to
rectify a material illegality in the report which is incapable of or unsuitable for rectification by the appeal and which
will have continuing adverse consequences for the applicant independently of the appeal or if such that if sought to
be cured by the appeal would have the effect that the issue or some wrongly excluded evidence involved would not
be reheard but would be examined only for the first time.” (F.O. v. MJELR (Unreported, Cooke J., 26th June, 2009,
IEHC 300)).
3. Accordingly, as the court has repeatedly pointed out in these judgments, leave to seek the intervention of the court
by way of judicial review in the asylum process before the appeal stage will not be allowed unless it is demonstrated to
the court that a compelling case is made out as to the existence of some material illegality in the s. 13 report which is
such that it is necessary for the court to intervene to cure it by way of judicial review because the statutory appeal will
be inadequate or unsuitable to do so.
4. The background of this case can be briefly stated. The applicant minor is now seven years old. She was born in
Vukovar in Croatia, formerly part of the Yugoslav Republic, in 2002. She arrived in the State with her parents in 2004. The
family are Croats of Serbian ethnic origin. The parents applied unsuccessfully for asylum but, following the judgment in the
Nwole case, the Minister invited the parents to make a separate application for asylum on behalf of the minor applicant in
this case. The applicant, accompanied by her father, was interviewed under s. 11 on 29th February, 2008, and the
authorised officer of the Commissioner issued the s. 13 report on 5th March, 2008. It contained a negative
recommendation.
5. The s. 13 report in the case starts with the presumption that the applicant is not a refugee. This arises by virtue of
the fact that Croatia has been designated as a safe country under s. 12(4) of the 1996 Act. Accordingly, the authorised
officer is required to proceed on the basis that the applicant is not to be declared a refugee unless reasonable grounds
are shown that she is a refugee.
6. The claim to a fear of persecution is based on her father’s description of the treatment she and her parents had
experienced before leaving Vukovar. Amongst various incidents recounted was one in which the minor applicant was with
her mother when the mother was attacked in the street - one of a number of occasions of attacks by a woman who was
apparently mentally ill. It is claimed that the police said they could do nothing about it because the woman was mentally
ill. It is claimed that if she is returned to Croatia the applicant would also have difficulties at school and would be
discriminated against in her education. She would not receive the medical treatment she needs for a bone disease and the
family faces restrictions, both in housing and in the practice of their religion as Orthodox Serbs.
7. In the Report, the authorised officer acknowledges these difficulties and the legacy of bitterness between Serbs and
Croats which has persisted since the post-independence conflict. The authorised officer essentially relies on two
particular documents in assessing whether Croatia can be considered an unsafe country for this family, notwithstanding
the presumption.
8. These documents are US Department of State International Religious Freedom Report of 2006 and a Department of
State Report on Human Rights in Croatia 2006. From these the authorised officer draws the conclusion that,
notwithstanding the slow progress and the problems and the bitterness that have persisted, the position is slowly
improving, violence is decreasing and that State protection is now available. The authorised officer then concludes:-
“The asylum process is essentially a forward looking one, and the crucial issue is whether the applicant would be at
risk of persecution if she were to live in Croatia. It is not unreasonable to suggest that Croatia, as a future EU
Member State and having to comply with EU standards will be able to afford protection to the Serb minority group
to which the applicant belongs. Mr. S. did not present any evidence that O. would be at risk of persecution in
Croatia. He has not submitted any reasonable grounds which would outweigh the general presumption that his
daughter is not a refugee.”
9. It is now sought to quash this report as unlawful on the basis of the statement of grounds which lists twelve proposed
grounds but which, as elaborated upon in oral submissions by counsel for the applicant, appears to the court to involve
the following essential contentions:-
(i) The first and most important attack is directed at the use of the country of the origin information in the report.
It is said that only the two documents obtained by the authorised officer are relied upon, that they were never put
to the applicant and that no opportunity was given to the applicant to comment on those documents. The
documents submitted on behalf of the applicant were ignored and no explanation was given as to why they were
rejected in favour of the officer's documents.
(ii) It is submitted that, as a result, the applicant's case has not been addressed and that, if confined to the
statutory appeal, her case will only be considered for the first time on the appeal.
(iii)It is argued that the report fails to have regard to and comply with the obligations accepted by the State in
ratifying the UN Convention on the Rights of the Child, in particular the authorised officer failed to make the rights
of the applicant child the primary consideration. In addition it is submitted that the report violates Article 12 of the
Convention by failing to afford the child the right to be heard.
(iv)A further ground is mentioned based on the proposition that the so called “O'Keefe test” does not apply when
reviewing an administrative decision such as the report under section 13 by the Commissioner. Instead, anxious
scrutiny should be applied and on that basis the Commissioner drew an incorrect or unreasonable conclusion in
relation to country of origin information because the case for refugee status was stronger than the case against it.
10. A number of other grounds are canvassed in the statement of grounds which were not mentioned in oral argument but
it is clear that none constitutes a basis for intervention by the court at this stage. Indeed, it is questionable whether any
of them are stateable as a basis for attacking a s. 13 report as such.
11. The court considers that none of the four specific grounds above suffices to place this case amongst the category of
exceptional cases which require intervention by judicial review.
12. First, the criticism of the treatment of the country of origin information. It is incorrect to say that the applicant’s
country of origin information was not considered by the Commissioner. Not only is it listed and mentioned in the report but
it is clear from the transcript of the interview that it was actually discussed at the interview. At p. 8 of the note the
interviewer says:-
“According to Irish law Croatia has been designated a safe country. From reading country of origin information, such
as UN documents and US State Department reports on Croatia and the documents you submitted, it is evident that
Serbs do face discrimination in Croatia. However, the country of origin information also states that the situation is
improving, albeit slowly, including in the area of housing. For instance, violence against ethnic Serbs has decreased
by 45% in 2006 compared with the previous year. A Serbian NGO noted better police performance and general
improvement of the political climate as factors that have led to the stability.” (emphasis added)
13. In the face of that it seems plainly incorrect to say that the documentation was not considered. The authorised
officer of the Commissioner is not obliged to enter into a debate, nor is he or she obliged to allow comment on country of
origin documentation when it is of a general character. This is not an adversarial hearing; it is an interview. It is the
function of the Commissioner to carry out an inquisitorial investigation and compile a report which goes with his
recommendation to the Minister. It is an information gathering exercise and an interview in which a specialist assessor is
required to make a personal appraisal of the applicant with a view to advising the Minister as to whether the applicant is
telling the truth. It is not an adversarial adjudication and thus not “a hearing” in that sense.
14. In any event, in this case the documents were not consulted, clearly, behind the applicant’s back or in a way in which
the applicant was deprived of an opportunity of making comments, as alleged. As already indicated, the two documents
were before the authorised officer at the interview, as the quotation from p. 8 above indicates and the gist of the
reliance placed upon them was actually stated at the interview.
15. Next, it is said that the alleged mistreatment or unbalanced appraisal of the country of origin documents means that a
written appeal is unsuitable and inadequate and that it would place the applicant at a continuing disadvantage in all
future steps in the asylum process. This argument is particularly difficult to understand in the circumstances of this case.
The complaint is that the country of origin information documents were wrongly used. It is explicitly stated that the
authorised officer misjudged the relative force of the case for and against Croatia being a safe country in treating and
examining the two sets of documents. If that is so, then the complaint is particularly apt for a written appeal because the
ground is based on the force of documentary evidence. It is not claimed that the issue as to whether Croatia is or is not
a safe country is in any way dependent on or influenced by some new oral information or testimony the applicant and her
father might wish to give.
16. That is the central and, really, the only issue which faces the applicant in this case. Has the presumption against
refugee status, arising from a designation of Croatia as a safe country, been displaced by the evidence given by the
applicant, or rather her father, such that whatever the general position might be, it is necessary to conclude that Croatia
is not safe for this particular family? That substantive issue is a matter for the appraisal by an authorised officer and for
the decision of a Tribunal member. It is not a matter for the High Court on judicial review. The court asked several times,
during the course of oral submissions, what the purpose of an oral hearing was proposed to be in this case? What was it
that the applicant wished to be heard saying by a Tribunal member that would serve to establish that the country she left
five years ago at the age of two was now unsafe to return to? Unfortunately, the court received no relevant or
meaningful reply to that question.
17. Next, the ground based on the Convention on the Rights of the Child. It is not disputed that the Convention is not
incorporated into Irish law, although ratified. Therefore even if an Article was shown to be ignored or infringed, it could
not form the basis of an annulment of an otherwise valid administrative decision taken by a competent authority. In any
event, the only specific Article relied upon here is Article 12 of the Convention which provides as follows:-
“1). States parties shall assure to the child, who is capable of forming his or her own views, the right to express
those views freely in all matters affecting the child, the views of the child being given due weight, in accordance
with age and maturity of the child.
2). For this purpose the child shall, in particular, be provided the opportunity to be heard in any judicial
administrative proceedings affecting the child, either directly or through a representative or an appropriate body, in
a manner consistent with procedural national law.”
18. That Article could not be said, in the court’s view, to have any bearing on the present case. This applicant has, in
fact, been heard. She was present at the interview. She can also be heard on any appeal by putting in a written
statement if she wishes to do so. Article 12 clearly recognises the entitlement of the contracting states to pursue the
objective of the Convention through the procedural rules of national law. Nothing precludes a child to whom it applies
being heard in a two stage procedure which is partly an interview and partly a written appeal. Moreover and above all,
reliance on this Convention and, in particular, on Article 12, is a strong reason for not granting leave in this case, rather
than for granting it. This is so because if the child has a right to be heard orally on appeal (quod non,) it is the decision of
the Tribunal on appeal without a hearing which would be flawed and not the s. 13 report.
19. Finally, the ground raised in relation to the O'Keeffe test, as it is called. It is difficult to understand the relevance of
this as a ground for quashing the s. 13 report. It is more an argument as to the approach and standard to be adopted by
this Court in exercising its judicial review. In so far as it is raised to support the criticism of the conclusion drawn by the
authorised officer from the documents consulted by way of country of origin information, it meets the same difficulty
already outlined above in respect of the more general attack on the authorised officer's treatment of that information and
is, accordingly, equally unfounded.
20. For all of these reasons leave must be refused.