BCG18 v Minister for Immigration and Multicultural Affairs [2025] FedCFamC2G 681

Note: The form of the order is subject to the entry in the Court's records.

Note: The Court may vary or set aside a judgment or order to remedy minor typographical or grammatical errors (r 17.05(2)(g) Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth)), or to record a variation to the order pursuant to r 17.05 Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth).

1. Before the Court is an application made under s 476 of the Migration Act 1958 (Cth) (Act) seeking review of a decision of the Immigration Assessment Authority (Authority) who affirmed a decision of a delegate (delegate) of the Minister refusing to grant the applicant a Temporary Protection (Subclass 785) visa (visa).

1. The applicant is a citizen of Iraq, who arrived in Australia as an unauthorised maritime arrival on 7 July 2013. On 21 September 2016, he applied for the visa (Court Book (CB) 26) and in his application included a separate statement of his claims (CB 85).
2. On 25 July 2017, the delegate notified the applicant that they had refused to grant the visa (CB 129).
3. On 31 July 2017, the delegate's decision was referred to the Authority for review (CB 147).
4. On 31 January 2018, the Authority affirmed the delegate's decision (CB 170).

1. Broadly, the applicant claims to fear harm because of:

(a) the deaths of his brother, cousins and friends caused by Sunni terrorist groups;

(b) forced conscription or recruitment into the Iraqi Security Forces (ISF) or the Popular Mobilisation Forces (PMF);

(c) his Shia religion; and

(d) his status as a person who would "fall under the profile of an individual with associations to members of the army and Iraqi authorities" (see [8] below).

1. The Authority identified that submissions provided to it by the applicant's (then) representatives (Authority Submissions) contained "several new claims that were not before the delegate" and other new information (CB 171 at [6] to [7]).
2. The first new claim was that the applicant fell within the profile of an "individual with associations to members of the army and Iraqi authorities" (CB 171 at [6]), which was said to increase the risk of harm to the applicant. The claim relied upon the 2012 UNHCR Eligibility Guidelines. The second new claim was directed to the applicant's ability to secure employment and government support.
3. In relation to each of the new claims, the Authority (at CB 171 at [7]):

(a) was not satisfied that the claims could not have been made earlier;

(b) was not satisfied that the claims were credible personal information;

(c) observed that the claims did not appear to be based on anything that had occurred since the delegate's decision, and relied on a "somewhat dated report";

(d) found that the above factors caused it to question the genuineness of the claimed fears; and

(e) observed that the applicant had not identified any exceptional circumstances to justify the new information and that it was not apparent what such exceptional circumstances might be.

1. In consequence of the above, the Authority declined to consider the new information.
2. More broadly, the Authority said that the applicant's evidence was consistent and persuasive in some respects, but general, vague, unpersuasive and contradicted by country information in others.
3. The Authority accepted that the applicant's brother was a soldier in the Iraqi Army and had been kidnapped and killed by a Sunni terrorist group in January 2013 (CB 173 at [17]). The Authority also accepted that the applicant may have had cousins and friends who joined the PMF and who were killed fighting ISIL in northern Iraq (CB 174 at [19]).
4. However, the Authority did not accept the applicant's claims as to conscription into the ISF and forced recruitment into the PMF (CB 174 to 176 at [20] to [28]). It found, based on country information, that the militias recruited volunteers only and that, contrary to the Authority submissions, there was no current conscription into the Iraqi Army (CB 175 at [26]).
5. While the Authority accepted that Shias had been subject to isolated attacks in the applicant's home area (CB 176 to 177 at [29] to [33]) it was satisfied that there was a lower risk of harm in that particular place compared to other areas in Iraq, and was further satisfied on the basis of the nature and frequency of incidents that the level of harm did not rise to a real chance of harm (CB 177 at [33]). The Authority found the applicant's evidence and claims of harm as a result of his religion, sectarian violence and insecurity were general, vague and unpersuasive (CB 177 at [33]).
6. Finally, the Authority was not satisfied that there was a real chance of harm arising from the Applicant's status as a failed asylum seeker (CB 177 at [35] to [36]). The Authority also observed that the applicant had not made any claims that he could not safely return to his home area (CB 177 at [37]).

1. At the time the proceedings were commenced the applicant was unrepresented, despite having been represented throughout the delegate and Authority phases. The proceedings were initially docketed to another Judge of the Court (first primary Judge). On 29 March 2018, a Registrar of the Court made orders by consent for the preparation of the matter for hearing before the first primary Judge. The applicant was given the opportunity to file an amended application and any evidence by 17 May 2018. The applicant did not avail himself of the grant of leave to amend, but did file an Affidavit, albeit out of time, being the Affidavit of Toufic Laba Sarkis filed on 30 May 2018 (Transcript Affidavit). Other than the Transcript Affidavit, the applicant has not filed any other documents in these proceedings in time, or at all.
2. The proceedings were later placed in the central migration docket and were called over before a Registrar of the Court on 29 November 2023 and again on 19 September 2024, on which occasion, orders were made for the preparation of the matter for hearing (September orders).
3. A notation to the September orders included that the first respondent's representative confirmed that a further copy of the Court Book would be provided to the applicant. From the Affidavit of Marcus James Vethecan made on 21 March 2025 and filed for the first respondent (Affidavit of Service), I can see that an additional copy of the Court Book had already been provided to a lawyer who purported to be assisting the applicant. The circumstances surrounding the provision of the Court Book are set out at [8] to [12] of the Affidavit of Service:

8. On 17 April 2018, persons previously in the employ of Clayton Utz caused a letter to be sent to the Applicant's physical address, enclosing a copy of the Court Book filed in these proceedings on 16 April 2018. A copy of that letter is annexed to this Affidavit and marked MJV-3.

9. On 10 March 2024 at 8.01am, I received an email from Mr Sam Hemachandra requesting a copy of the court book these proceedings. In response on 19 March 2024 at 10.09am, I requested Mr Hemachandra provide authority from the Applicant. On 20 March 2024 at 4.31pm, I received an email in reply attaching the signed authority and confirming that Mr Hemachandra was not acting for the Applicant in these proceedings. On the same day, I replied to the email, attaching the sealed court book filed on 16 April 2018.

10. On 4 April 2024 at 3.54pm, I received an email from Mr Hemachandra requesting a copy of the DFAT/Iraq/2017 report. On 5 April 2024, I replied to that email, attaching the country report.

11. A copy of the email chain referred to in paragraphs [9] and [10] above and the Applicant's signed authority are annexed to this affidavit and marked MJV-4.

12. On 19 September 2024, I caused an email to be sent to the Applicant's email address and the Applicant's updated email address attaching the sealed Court Book filed on 16 April 2018. A copy of that email is annexed to this affidavit and marked MJV-5.

1. However, despite what has emerged from the correspondence put before the Court today in the Affidavit of Service, no appearance has ever been filed for the applicant to indicate that he is legally represented in these proceedings.
2. On 14 January 2025, the proceedings were docketed to me, and I made orders on that date listing the matter for hearing before me at 2:15pm on 10 March 2025, in Sydney. These proceedings, were commenced in the Sydney Registry of the Court and were docketed to me on the basis that the applicant not only commenced them in that Registry but has never changed his Notice of Address for Service from being the New South Wales address included in the originating application.
3. By the orders I made in January of this year, the applicant was again granted leave to amend and was required to file any additional Affidavit evidence and a written outline of submissions by 10 February 2025. As noted earlier, he did not do so. On 25 February 2025, the Court received correspondence from a person claiming to be an accredited NAATI interpreter in the Arabic language (February email). That was copied to a Gmail address which seemed to indicate the applicant's name but ended in a particular three-digit number. At [5] to [6] of the Affidavit of Service, it states:

Service of Filed Materials

5. I note that in the Application for Review field in these proceedings by the Applicant on 7 March 2018 (Application), the Applicant gives [gmail address] as an "Address for Service" (the Applicant's email address). The Applicant also gives [a New South Wales street address] as the physical address for service (the Applicant's physical address).

6. On 29 November 2023, I emailed the Court to provide the updated contact details of the Applicant being [updated gmail address] (the Applicant's updated email address) and [another New South Wales street address] (the Applicant's updated physical address).

1. The contents of the email dated 29 November 2023 referred to at [6] of the Vethecan Affidavit is as follows:

Dear Migration Team

We refer to the above matter, which was listed for callover before Registrar Carney this afternoon.

As requested by Registrar Carney, our client has notified us that the current contact details it holds for the applicant (which differ from those listed in his application) are as follows:

• [the Applicant's updated physical address]
• [the Applicant's updated email address]

1. In the interests of abundant clarity, even if the Court becomes aware of alternate contact details for an applicant, unless and until a Notice of Address for Service is filed pursuant to r 6.01 of the Federal Circuit and Family Court of Australia (Division 2) (General Federal Law) Rules 2021 (Cth) (Rules), service can only be effected properly under the Rules by using addresses that were given formally in the originating application. There may be many circumstances in which parties to proceedings (or the Registry) becomes aware that there are alternative contact details for a party and, out of an abundance of caution, it may be prudent to send documents to additional addresses as well. However, the Rules exist for a reason and parties to litigation should be entitled to rely upon the presumption of regularity that compliance with those Rules provides.
2. By the February email, the Court was informed that the applicant had moved from Sydney to Perth. A request was made that the hearing be facilitated by video-link because it would be difficult for the applicant to travel from Perth back to Sydney for the hearing. In circumstances where it was the Court's preference that the applicant appear in person and given that the Court was due to be sitting in Perth in the week commencing 24 March 2025, I adjourned the matter so that the applicant could attend in person, and the first respondent's solicitor could instead appear by Microsoft Teams. In notifying the parties of this change, the email address used to correspond with the applicant was that which was provided by his originating application. The contents of the reply email, are as follows (anonymisation added):

Dear parties

I refer to the below email from [name], sent to the Court ex parte. This response is being sent to the email contained on the applicant's application filed on 7 March 2018, and not to the variant to which the below email was sent, which is a different email address. If the applicant's contact details have changed, the applicant, needs to file an updated Notice of Address for Service with the Court's Registry.

In relation to the below request, it is Judge Given's preference that the applicant attend the hearing in person.

Her Honour will be sitting in Perth from the week commencing 24 March 2025.

Accordingly, the proceedings have been relisted to 10:15am on 26 March 2025. The proceedings will occur in person, at a Court Room to be advised, at the Peter Durack Commonwealth Law Courts Building, 1 Victoria Ave, Perth.

I confirm that an interpreter in the Arabic language will be arranged by the Court.

Please ensure any future correspondence to the Court copies all parties to the proceedings.

Sincerely,

1. The parties appeared before me this morning at 10:15am (AWST) (1:15 pm (AEDT)).

1. When the matter commenced, there was no appearance by (or for) the applicant in the courtroom. The solicitor for the Minister and an interpreter in the Arabic language were present in the Microsoft Teams forum. I had the matter called outside the courtroom which yielded an appearance by the applicant in person. At the commencement of the hearing, the Court explained to the applicant its role and the limitations on what can be decided in this review, at the conclusion of which, the applicant made an adjournment application on the basis that he wished to be legally represented and that he had not been able to obtain an appointment with his preferred lawyer. The applicant said that since she (being the aforementioned lawyer) was not able to appear for him, he would also want more time to find another lawyer to appear.
2. The first respondent opposed the adjournment.
3. The Court refused the application on the following bases.
4. These proceedings have been on foot since 7 March 2018, which arguably means the applicant can be taken to have had seven years to prepare for today and/or obtain legal representation. More specifically, the Court made orders on 14 January 2025 listing the proceedings for hearing on 10 March 2025. That hearing was then moved to accommodate the applicant's circumstances, namely that he now resided in Perth, the result of which was the hearing was postponed by an additional two weeks.
5. From correspondence annexed to the Affidavit of Service, it became apparent that the applicant had retained a lawyer in relation to other matters since at least March of 2024 and who had been corresponding with the first respondent's solicitors in these proceedings, although has never filed an appearance for the applicant in this case. While it was difficult to believe that in the space of the last two months since this hearing was listed, the applicant had not been able to obtain a single appointment with the lawyer in question, to the extent that the applicant indicated a desire to obtain different legal representation, there was no evidence he had taken any steps to do so.
6. Despite the fact that the Court has been corresponding with the applicant for some weeks in relation to today's hearing, this is the first time he has informed the Court of:

(a) having a lawyer;

(b) the alleged difficulties in obtaining an appointment with her; and

(c) the request to adjourn the hearing further.

1. That is despite the fact that the correspondence annexed to the Affidavit of Service seemed to indicate that the lawyer had been acting for him in other matters for at least a year.
2. The Court was not satisfied that there would be utility in allowing the matter to go over simply for the applicant to obtain an appointment with a lawyer whom he ought to have been able to see by now, much less to find another lawyer, having particular regard to the length of time since the commencement of the proceedings and that there is not right to legal representation in migration proceedings: see AMF15 v Minister for Immigration & Border Protection [2016] FCAFC 68; (2016) 241 FCR 30 at [51] per Flick, Griffiths and Perry JJ and SZHTI v Minister for Immigration & Multicultural & Indigenous Affairs [2006] FCA 702 at [4] per Gyles J.

1. The Court received the Transcript Affidavit for the applicant, without objection. In circumstances where the Affidavit in support of the originating application only served to annex the Authority's decision, I did not have regard to that document, the Authority's decision now appearing in any event in the Court Book. The Minister tendered the Court Book, which was marked as Exhibit "1R", and also read the Vethecan Affidavit, which goes to several of the matters to which I have already adverted. There was no objection to either the tender of the Court Book, nor to that Affidavit being read.
2. The Minister filed written submissions, as ordered. The Court also provided to the applicant during the course of the hearing paper and pen so that he could make notes during the solicitor for the Minister's submissions. The applicant, not having availed himself of the multiple opportunities to amend during the life of these proceedings. The grounds of review are those contained in the originating application, and are as follows (particulars omitted):
   1. The second respondent has ignored relevant material in making their decision.
   2. The second respondent has illogically and unreasonably applied the facts of the case in making their finding.
3. I had those grounds interpreted to the applicant together with their particulars, and he was given the chance to address them in turn.

1. In respect of ground 1(a), the applicant said that when he received the first decision, he objected to the conclusions that Iraq is safe. I asked the applicant whether he was referring to the decision of the delegate or the Authority. The applicant then said that he was confused and asked what was meant by the "IAA" because he did not have a recollection of having applied to or appeared before that body.
2. The Court explained to the applicant that he was correct that he did not appear before the Authority and that neither he nor his lawyer had applied. The Court explained that because he was considered to be a "fast-track" visa applicant his application had automatically been referred to the Authority after the delegate refused to grant him the visa. The Court observed from the material in the Court Book that on 1 August 2017, the Authority wrote to the applicant at his address in Guildford, NSW to notify him of that referral. It can be inferred that the applicant then passed details of that referral to his lawyer at the time because they then notified the Authority that they would be representing him in the review, and later made the Authority Submissions on his behalf. The Court explained that the Authority review ordinarily takes place "on the papers" and it is for this reason the applicant does not recall appearing before the Authority. The applicant acknowledged understanding this process, describing the decision of the Authority as the "second rejection".[1]
3. When asked again to address the ground, the applicant said that he did not have much to say. The applicant said that there was not sufficient evidence to say that Iraq was safe and that he could return. The applicant said he was not convinced with either the decision of the delegate or the Authority. The applicant asked how it was that the Authority had come to the conclusion that it was safe and again asked rhetorically: "What was their evidence?"[2]
4. In respect of ground 1(b), the applicant said that when he came to Australia, his claim was that he was being forced to join the army. The applicant said that he did not have anything to say about errors, and that all he knew was that he had a lawyer on the ground that the decision said that it was safe for him to go back. After some discussion with the applicant, it was apparent that his main complaint in ground 1 is a simple disagreement with the conclusions that the Authority came to.

1. The first respondent submitted that the applicant had broadly expressed dissatisfaction with the reasons of the delegate and the Authority and was seeking to use the hearing as a vehicle for impermissible merits review. In respect of the submissions made at hearing today, I agree.
2. Addressing the grounds as they are raised, ground 1 goes to the question of the Authority's treatment of new information, which turns upon the claims made in the written submission from the applicant's then lawyer to the Authority on 21 August 2017. That passage at CB 162 is as follows:

The Department has previously referenced the following country information:

'The 2012 UNHCR Eligibility Guidelines place individuals associated with, or

perceived to be supporting the Iraqi authorities, including members of the

army, security and intelligence apparatus, likely to be in need of international

refugee protection because of the their (imputed) political opinion'

We submit that the applicant would fall under the profile of an individual with

associations to members of the army and Iraqi authorities. This profile will increase

the risk of harm for the applicant and given his siblings in Iraq are married with

children, he will be perceived as the only single, able-bodied male who poses a

threat against groups such as ISIS.

1. The applicant now contends the Authority Submissions did not present new facts or circumstances but only asked the Authority to consider existing information in a different perspective. The applicant says that, so understood, s 473DD of the Act had no application because there was no new information before the Authority.
2. In CVK16 v Minister for Immigration and Border Protection [2017] FCA 1434 at [49] to [51], McKerracher J rejected a submission (in the context of s 473DD), that there was:

no impediment on the Authority considering new claims based on the same existing information.

and his Honour agreed with the primary judge, who had found that "it was artificial to distinguish between "claims" and "information"": see CVK16 (supra) at [45].

1. The first respondent says the question is then whether an existing claim was ever before the Authority.
2. It is apparent that the applicant did not claim that he would "fall under the profile of an individual with associations to members of the army and Iraqi authorities".[3] I accept the submissions of the first respondent that no such claim is found in the arrival interview documents,[4] the statement of claims which accompanied the protection visa application,[5] or arising in the protection visa interview (CB 135). Nor were the 2012 UNHCR Guidelines upon which the applicant relied in the material considered by the delegate. Accordingly, I accept the submission of the first respondent that the applicant's reliance upon the 2012 UNHCR Guidelines, and claims based on familial association were required to be considered as "new information" and to pass through the s 473DD test.
3. Lastly, in respect of ground 1, in his capacity as a model litigant, the first respondent also raises a potential argument which might be available to the applicant, by reference to the error identified by the Full Court of the Federal Court in CWP16 v Minister for Immigration and Border Protection (2018) 260 FCR 284 per Robertson, Kerr and White JJ.
4. In the present case, the delegate considered whether the applicant or his family members would be pursued by ISIS as a result of their familial association with his brother, and found that the prospect of being targeted by ISIS on the basis of his brother's previous work for the Iraqi Army to be remote (CB 139). However, even if the delegate's comments were taken to form part of the review material which ought to have been considered by the Authority (Cf CWP16 (supra) at [44]) and noting that the delegate's comments were not prompted by any claims or submissions by the applicant, I accept the submissions often first respondent that it is apparent the Authority did consider the prospect of harm based on familial association when it found that:

(a) there was not a real chance now or in the reasonably foreseeable future of any action directed at the applicant as a consequence or in connection with the deaths of his brother, his cousins and friends;[6]

(b) the applicant's claims to fear harm as a result of his religion, sectarian violence and insecurity were general, vague and unpersuasive;[7] and

(c) the chance of the applicant suffering harm returning to his home area was remote at the time of decision and in the reasonably foreseeable future.[8]

1. I agree with the first respondent's submissions, including in respect of the alternative pathway even if the delegate's reasons could be taken to form part of the review material. I am satisfied that the Authority dealt with these appropriately but that, even as an alternative, had the information arisen, it was dealt with appropriately under s 473DD of the Act and that even if the new claims had somehow passed through that prism successfully such that they were to be considered, there is no material error: see LPDT v Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2024] HCA 12; (2024) 418 ALR 152 at [7] per Gageler CJ, Gordon, Edelman, Steward, Gleeson and Jagot JJ.

1. By this ground the applicant alleges that the Authority illogically and unreasonably applied the facts in reaching their findings. The particulars to the ground allege that the Authority relied on outdated information. However, when the ground was interpreted to the applicant he asked the Court what was meant by the term "outdated".[9] It was explained to the applicant that this was his ground, and it was for him to identify what the error was on the part of the Authority in relation to how it dealt with independent country information.
2. The applicant then made submissions (repeated during his submissions in reply) to the effect that there was no information before the Authority to the effect that the applicant's safety in Iraq could be guaranteed. The Court explained to the applicant during the hearing that the requisite tests contained in the Act do not require a guarantee of safety.
3. At hearing, the solicitor for the Minister made submissions to the effect that treatment of independent country information is a matter for the Authority. I would add to this that the choice of country information is a matter for the Authority: see NAHI v Minister for Immigration & Multicultural & Indigenous Affairs [2004] FCAFC 10 at [11] to [13] per Gray, Tamberlin and Lander JJ and that there is no error in and of itself constituted by using older information: see VQAB v Minister for Immigration and Multicultural and Indigenous Affairs [2004] FCAFC 104 at [26] and [32] per Beaumont, Weinberg and Crennan JJ.
4. Turning then to how the country information was address, as the first respondent correctly submits, the Authority expressly recognised that country information before the delegate, namely a DFAT Report dated 13 February 2015 (2015 DFAT Report), had been superseded by a more recent DFAT report dated 26 June 2017 (2017 DFAT Report) (CB 172 at [8]). The Authority stated that it was satisfied that there were exceptional circumstances to justify considering this new information, and the Decision Record demonstrates that the Authority did rely upon the more recent 2017 DFAT Report (see CB 173 to 174 at [17] and [19] and CB 176 and 177 at [32] and [35]). There is no evidence that the Authority relied upon the 2015 DFAT Report.
5. The solicitor for the first respondent submitted that the Authority referred to a number of pieces of country information regarding the security situation in Iraq and that it was not clear which pieces of country information the applicant alleges are outdated. I have considered in particular [26] and [32] of the Authority's reasons, where it refers to country information which is set out in its footnotes. Paragraph [26] refers to multiple pieces of country information which confirm that militias recruit volunteers. By reference to the dates in footnotes 5 and 6 thereto, the information in question spans from 2003 to 2016. Later in [32], the Authority had regard to the 2017 DFAT report, which post-dates the applicant's arrival in Australia and was only some six months before the Authority's decision was made.
6. I accept the submission of the first respondent that there is no error in the Authority having used that information to find there was not a real chance that the applicant would be forcibly recruited by the PMF, nor that there is any error in the manner in which the Authority reasoned at [32] about the security situation in Iraq. The information before the Authority indicated that Shias in Baghdad faced a moderate risk of violence, whereas Shias in other areas, such as the south, faced a lower risk of violence. Again, that was by reference to information in the 2017 DFAT report.
7. Finally, it must be noted that the Authority considered in detail the applicant's claims that there would be a risk of harm either from forced conscription or recruitment into the ISF or PMF (CB 174 to 176 at [20] to [28]), or more generally in the applicant's home area as a result of his Shia religion, actions by Sunni militias, or the result of insecurity in that governorate (CB 176 to 177 at [29] to [33]).
8. In reply, the applicant said that he agreed with many of the first respondent's submissions made at hearing. In respect of the prospect that he might be forcibly recruited, the applicant again submitted that there was no guarantee that he would not be. The applicant said that he had provided his evidence about the risk to him in Iraq and that people in the south (particularly the Shia) were being targeted. For the reasons to which I have just referred, in particular, the country information cited at [32] (CB 177 to 178) of the Authority's decision, I am satisfied that its conclusions to the contrary were open to the Authority on the material that was before it. The applicant also asked that the Court take into account the years that he has spent in Australia. I took the time to explain to the applicant that that was a matter that was not relevant to the Court's task and there are no compassionate grounds on which the matter could be remitted absent a jurisdictional error.

1. I am satisfied that the decision of the Authority is without error. It is therefore a privative clause decision and must be dismissed. I will make orders to that effect.

1. Consequent upon the dismissal of the application, the first respondent makes an application seeking costs fixed in the current scale amount, which is $8,371.30. When asked what he wanted to say about whether costs should follow the event and, if so, in what amount, the applicant said that he would try to pay some of the amount if he could, and he asked whether or not he could seek review of the decision made today.
2. I indicated to the applicant that I would be making an order which will form order 3 of the orders made today and explained the effect of that. I also directed the applicant to remain in Court to complete a Notice of Address for Service form so that each of the Court and the first respondent could be assured that any further correspondence in this proceeding goes to the applicant at the correct addresses for service in Perth, for the reasons that I have already outlined today. In this proceeding, I am satisfied that costs should follow the event. I am also satisfied that the amount sought by the first respondent is reasonable and will make an order that the applicant pay the first respondent's costs in the fixed amount sought.

I certify that the preceding sixty (60) numbered paragraphs are a true copy of the Reasons for Judgment of Judge Given.

[1] Transcript dated 26 March 2025 (Transcript) at T9.27

[4] CB 1 to 20 and Annexure "A" to the Transcript Affidavit