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[2021] FCA 1568
Federal Court of Australia
2021-12-16
Jagot J
Original judgment source is linked above.
2.1 First IAA decision 4 The appellant is a Faili Kurd from Iraq. He arrived in Australia on 16 August 2013. 5 On 16 September 2016, the appellant applied for a protection visa (a Safe Haven Enterprise (subclass 790) visa (SHEV)). 6 On 14 March 2017, the Minister refused the visa application on the ground that the appellant was not a person in respect of whom Australia has protection obligations. 7 As required by s 473CA of the Migration Act 1958 (Cth) (the Act), the Minister referred the decision to the IAA for review. 8 The IAA affirmed the decision of the Minister on 12 May 2017. 9 The appellant applied to the Federal Circuit Court for judicial review of the IAA's decision. The appellant contended that, amongst other things, the decision of the IAA was affected by apprehended bias by reason of the IAA receiving and considering prejudicial material about the appellant that had been provided to it by the Secretary of the Department of Immigration and Border Protection which was irrelevant to the statutory criteria for the determination of the right to be granted a protection visa. 10 The Federal Circuit Court dismissed the appellant's application: CNY17 v Minister for Immigration & Anor [2017] FCCA 2731. 11 The appellant appealed. The Full Court of the Federal Court of Australia dismissed the appeal: CNY17 v Minister for Immigration and Border Protection [2018] FCAFC 159; (2018) 264 FCR 87. 12 The High Court allowed the appellant's further appeal, quashed the decision of the IAA, and ordered that the matter be remitted to the IAA differently constituted: CNY17 v Minister for Immigration and Border Protection [2019] HCA 50; (2019) 268 CLR 76 (CNY17 HCA). 13 In CNY17 HCA Kiefel CJ and Gageler J (in the minority as to the result) said: [17] What the bias rule requires of the Authority is that its conduct and that of the Minister and the Secretary is never such that a fair-minded lay observer properly informed as to the nature of the procedure for which Pt 7AA provides might reasonably apprehend that the Authority might not bring an impartial and unprejudiced mind to the resolution of the factual and legal questions that arise for its decision in the conduct of a review… … [20] The question whether conduct has resulted in a breach of the bias rule falls to be determined in light of the totality of the circumstances that exist at the time when that question arises. Where the question arises for determination after the Authority has made a decision on a review, the totality of the circumstances includes the decision and the reasons that the Authority has given for the decision. [21] Establishment of an apprehension of bias on the part of the Authority then requires the taking of two essential steps: first, identification of the factor which it is postulated might have led the Authority to have decided the review otherwise than on an independent and impartial evaluation of the merits; and, second, articulation of how that factor might have led the Authority to have decided the review otherwise than on an independent and impartial evaluation of the merits. Taking those two steps is necessary to provide the foundation for the third and critical step in the application of the bias rule. That is the step of assessing whether the fair-minded lay observer might reasonably apprehend in the totality of the circumstances that the articulated departure might have occurred. In taking that third step, "it is the court's view of the public's view, not the court's own view, which is determinative". [22] Stepping through that analysis in respect of the conduct of the Secretary in having given irrelevant but prejudicial material to the Authority allows for the recognition of two quite distinct ways in which the material might conceivably be apprehended by the fair-minded lay observer to have compromised the independence or impartiality of the Authority in the conduct of the review. [23] To the extent that the fair-minded lay observer might interpret the material as a communication to the Authority of the opinion of the Secretary about the character of the referred applicant or about the worthiness of the referred applicant to be granted a visa or about the merits of the decision of the Minister to refuse to grant the referred applicant a protection visa, the hypothetical fair-minded lay observer can be expected to be reluctant to discount as unrealistic the possibility that the Authority might have been influenced by that communication. The fair-minded lay observer would expect the Authority and the Secretary to adhere scrupulously to the standard expected of a court and court officer of avoiding any private communication of opinion pertaining to the review and would view any departure from that standard with justifiable suspicion. … [25] Within the cloistered and non-adversarial context of Pt 7AA, there is a structural consideration which makes that general concern more acute. It is the marked discrepancy in hierarchical position between the Secretary, on the one hand, and a Reviewer engaged under the [Public Service Act 1999 (Cth)], on the other. That discrepancy would make any communication from the Secretary to the Authority that might smack of instruction, advice or opinion concerning the conduct or outcome of a review a matter of grave concern. [26] To the extent that the fair-minded lay observer might interpret material given to the Authority by the Secretary not as instruction, advice or opinion concerning the conduct or outcome of a review but merely as material capable of founding an inference on the part of the reader that the referred applicant is a person of bad character or a person who is in some way (unrelated to the applicable criteria for the grant of a protection visa) unworthy of being granted permission to remain in Australia, the hypothetical fair-minded lay observer can be expected to be more circumspect. … [28] The fair-minded lay observer would recognise that although the Authority is not a court and although a Reviewer is not necessarily a lawyer, the Authority as constituted by a Reviewer is a professional decision-making body that can ordinarily be expected to be capable of discarding "the irrelevant, the immaterial and the prejudicial". But, the fair-minded lay observer must also be taken to recognise that even a professional decision-maker is not "a passionless thinking machine" and that information consciously and conscientiously discarded might still sometimes have a subconscious effect on even the most professional of decision-making. (Citations omitted). 14 Kiefel CJ and Gageler J thus identified two logical paths by which the "double might" test for apprehended bias might be satisfied, being that, first, the fair-minded lay observer might apprehend the Secretary's provision of the irrelevant prejudicial material as an instruction, advice or opinion to the IAA concerning the conduct or outcome of the review or, secondly, might infer from the material that the appellant was "unworthy" of a protection visa (a consideration irrelevant to the grant or refusal of a protection visa). Their Honours said the fair-minded lay observer would be "justifiably suspicious" about the first path and "more circumspect" about the second path. 15 However, Kiefel CJ and Gageler J were not satisfied that either path to a conclusion of apprehended bias was ultimately available in all of the circumstances of the first IAA decision. 16 Nettle and Gordon JJ (part of the majority in CNY17 HCA) said at [51]: The source of the apprehended bias is the irrelevant and prejudicial material. That material might have led the decision-maker to make a decision otherwise than on the legal and factual merits of the case because it might have led the decision-maker to the view that the appellant was not the sort of person who should be granted a visa or that the appellant was not a person who should be believed. A fair-minded lay observer might have apprehended that this might have had an effect on the decision-maker, even if that effect was subconscious. (Citations omitted). 17 Nettle and Gordon JJ also said at [106]: The Minister contended that quashing the decision of the IAA and remitting the matter back to it would put the IAA in an "impossible bind", because the IAA would once again be exposed to the prejudicial material. Any further decision it made would, therefore, be infected by the same apprehended bias found in this appeal. That submission should not be accepted. Section 473EA(4) of the Migration Act requires the IAA to return to the Secretary those documents provided by the Secretary, after the IAA's review is complete. Moreover, the matter would be remitted to a differently constituted IAA. As a result, the "impossible bind" spoken of by the Minister would not arise. The relief would not be futile. 18 Edelman J agreed with the conclusion of Nettle and Gordon JJ: at [109]. 19 Edelman J said at [135]: Apprehended bias must be assessed by reference to all the circumstances existing at the relevant time of enquiry. If apprehended bias is assessed at the conclusion of a hearing, as the appeal in this case requires, then the reasons for decision might reveal matters relevant to the consideration of whether a reasonable apprehension exists. It would be absurd if, on the one hand, remarks made by the decision maker during the course of a hearing could be considered as part of an assessment of the presence of reasonable apprehension of bias but, on the other hand, remarks at the conclusion of the proceeding could not. However, remarks at the conclusion of a proceeding or in reasons for decision are only one of the circumstances to take into account. In Michael Wilson & Partners Ltd v Nicholls [[2011] HCA 48; (2011) 244 CLR 427 at 446 [67]], a joint judgment of four members of this Court cautioned against the error of assuming a reasonable apprehension of a decision maker's bias and using comments in the reasons for judgment by the decision maker to "confirm, enhance or diminish the existence of a reasonable apprehension of bias".
2.2 Second IAA decision 20 The IAA notified the appellant on 19 December 2019 that the matter had been remitted to the IAA for reconsideration. 21 The IAA wrote to the appellant (via his lawyers) on 15 January 2020. This letter said: The IAA has received the material referred by the Secretary under s.473CB of the Migration Act 1958 (the Act) (the review material). This includes a copy of the High Court decision CNY17 and Minister for Immigration and Border Protection and Anor [2019] HCA 50. This decision contains references to, and general descriptions of, 48 pages of information that the Secretary provided the IAA in 2017 (see [33]-[37], [81], [111] and [119]-[124]). Those documents have not been provided to the IAA with the review material in the present matter and are not before the IAA. This information does not appear on its face to be relevant to the review. However, if you wish to do so you are invited to comment on the information referred to in the Court's decision. 22 In response to a letter in reply querying the relevance of the High Court decision, the IAA wrote again to the appellant (via his lawyers) on 21 January 2020 saying: To avoid any doubt, the IAA does not consider the information identified in the High Court decision (and our letter of 15 January 2020) to be relevant and does not intend to consider it. The IAA does not consider that the information would be the reason or part of the reason for affirming the decision under review. Having regard to the High Court's observations at [101]-[103], [124] and [141], the IAA is providing opportunity to comment on this approach. Please provide any response, including confirming if you do not wish to comment further, by 24 January 2020. (Emphasis in original). 23 On 29 January 2020, the appellant's lawyers responded saying: 3. Given the Secretary provided the prejudicial material to the Authority under s 473CB, the Secretary considered the prejudicial material 'to be relevant to the review': s 473CB(1)(c). Section 473DB(1) of the Act prescribes that the Authority 'must review a fast track reviewable decision referred to it under section 473CA by considering the review material provided to the Authority under section 473CB' (emphasis added). 4. Therefore, as the Secretary has decided that the prejudicial material is 'relevant', the Authority is compelled to consider it. This is regardless of the fact that the Authority's letter of 21 January 2020 states it 'does not intend to consider it'. 5. Any attempt to neutralise the risk of bias by affording [the appellant] an opportunity to comment on the prejudicial material, will not necessarily erase the risk of subconscious prejudice: see Minister for Immigration and Border Protection v AMA16 [2017] FCAFC 136 per Griffiths J at [75]. 6. In light of the above, [the appellant] requests that the matter be reconstituted to a different reviewer, without a copy of the prejudicial material. (Emphasis in original). 24 On 4 February 2020, the IAA affirmed the decision of the Minister to refuse to grant the appellant a protection visa under s 473CC(2)(a) of the Act. The IAA's reasons include this: 4. I have considered the material given by the Secretary under s.473CB of the Migration Act 1958 (the Act) (the review material), subject to the following. 5. The [appellant]'s SHEV application and the delegate's decision refer to the [appellant] being charged with offences relating to an incident while he was in immigration detention. The High Court's decision in respect of the first IAA decision states that there was certain additional information in the material provided to the IAA in 2017 that, in the Court's view, was not relevant to the review. As foreshadowed by the Court, that information is not included in the review material that is now before me, nor is it referred to in the [appellant]'s submissions to the IAA (considered further below). However, it is described and summarised in the Court's decision, which is in the review material. On 15 January 2020, the IAA wrote to the [appellant] (via his agent) advising [that it had received a copy of CNY17 HCA from the Secretary, that the information referred to in the decision did not appear to be relevant to the review, and providing the appellant with an opportunity to comment on the information]. … 7. On 29 January 2020 the [appellant]'s agent sent a further response on behalf of the [appellant], which expressed the view that the IAA would be compelled to consider the prejudicial material and that affording the [appellant] an opportunity to comment would not necessarily erase the risk of subconscious bias. The response conveyed a request from the [appellant] for the matter to be reconstituted to a different Reviewer, without a copy of the prejudicial material. 8. I have taken the [appellant]'s response into account; however the Secretary did not provide the "prejudicial material" that was provided to the first Reviewer, but only the High Court decision itself, which is before me in any event, as the judgment remitting this matter to the IAA. To the extent that the High Court decision refers to the prejudicial material, it is in the context of general descriptions and is not the actual material itself. For clarity I confirm that although I am aware that the [appellant] has been charged with offences while in immigration detention, the offences (as he disclosed in the SHEV application) are irrelevant to the [appellant]'s credibility, his claims for protection and my assessment. I have not found it necessary to further consider this issue. In making my assessment, I have disregarded the information in those parts of the High Court's judgment which summarise and describe the irrelevant information given to the IAA in 2017. 25 As noted, the Federal Circuit Court dismissed the appellant's judicial review application of the second IAA decision including on the ground of apprehended bias alleged to result from the Secretary providing the reconstituted IAA with a copy of CNY17 HCA. 26 The appellant's appeal to this Court is on a single ground as follows: The primary judge erred in finding that the [IAA] statement that it would not consider the prejudicial but irrelevant material that was before it was sufficient to assuage the risk that a reasonable observer might apprehend that the IAA's decision might be affected by subconscious bias in respect of that material.
CNY17
Minister for Immigration, Citizenship, Migrant Services and Multicultural Affairs
[2021] HCA 29
[1982] HCA 78
(2005) 225 CLR 88
(2021) 393 ALR 389
(1982) 154 CLR 25
(2018) 264 FCR 87
(2019) 268 CLR 76
(2020) 274 FCR 456
(2011) 244 CLR 427
(2017) 254 FCR 534
[2005] HCA 72
[2011] HCA 48