Case summaries

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UK - Court of Appeal, AA (Iran), R (on the application of) v Upper Tribunal (Immigration and Asylum Chamber) & Anor, [2013] EWCA Civ 1523
Country of applicant: Iran

This case concerns the State’s obligation under Article 19(3) of the Reception Direction to trace the family members of unaccompanied child asylum applicants.  The Court considers the effect on their claims where there is a failure by the State to carry out that duty.

Date of decision: 26-11-2013
Relevant International and European Legislation: 3.,Article 8
UK - High Court, Hashemi, R (on the application of) v The Upper Tribunal (Immigration and Asylum Chamber) & Anor, [2013] EWHC 2316 (Admin)
Country of applicant: Afghanistan

This case concerns a child asylum applicant who had his appeal against refusal of asylum considered after he had turned 18, and thus had become an adult. He complained that this breached Article 39 of the Procedures Directive (effective remedy).

Date of decision: 31-07-2013
Relevant International and European Legislation: Art 23.2,Art 4,Recital 1,Art 39,Art 13,Art 23,Recital 27,Art 17,Art 23.1,Art 23.2,Art 39,Recital 13,Recital 8,Recital 14,Art 39.1 (a),Art 39.1 (e),3.,UN Convention on the Rights of the Child
UK - Upper Tribunal (Asylum and Immigration Chamber), AK (Article 15(c)) Afghanistan CG, [2012] UKUT 163 (IAC)
Country of applicant: Afghanistan

There is not currently an indiscriminate conflict in Afghanistan (as a whole, or in any province) within the meaning of Article 15(c). Internal protection is in general possible in Kabul; however it is unreasonable to expect certain categories of women to seek internal protection within Afghanistan.

Date of decision: 18-05-2012
Relevant International and European Legislation: Art 15 (c),Art 15 (a),Art 15 (b),Art 8,Art 9,Art 24.2,Art 4,Recital 25,Art 8,3.,Article 2,Article 3
UK - Court of Appeal, HK (Afghanistan) & Ors v Secretary of State for the Home Department, [2012] EWCA Civ 315
Country of applicant: Afghanistan

This case concerns the State’s obligation to attempt to trace the family members of unaccompanied minor asylum seekers.

Date of decision: 16-03-2012
Relevant International and European Legislation: Art 15 (c),3.
Slovenia - Administrative Court of the Republic of Slovenia, 14 february 2012, I U 42/2012,
Country of applicant: Afghanistan

When reaching a decision, the Defendant should have protected the best interest of the child. Taking into account the fact that the Applicant is a minor and providing legal representation for a minor applicant, are necessary elements in the process of demonstrating and establishing the facts. The principle of protecting the best interest of the child has to be enforced when assessing the risk that the absolute rights of the child might be violated if he is returned to his country of origin and needs to be reflected in the Defendant’s burden of proof as well as in the rules and standards of  evidence (in relation to subsidiary protection).

The Defendant should already have started searching for parents during the procedure for international protection and not only once the procedure for removing the child from the state has begun.   

Threats and violence against a person’s family members can be considered as acts of persecution where that person is connected to the facts which previously led to the violence..

The Plaintiff needs to state all circumstances known to him in relation to his persecution; however he does not need to establish a material and legal connection between the persecution and the reasons for persecution.

The fact that somebody is a child in Afghanistan can mean that he belongs to particular social group.

Date of decision: 14-02-2012
Relevant International and European Legislation: Art 17,Recital 12,Art 20,Article 24,Art 24.2,Art 24.3,Art 20.5,3.,Article 3,UN Convention on the Rights of the Child