Ikupu v Minster for Immigration, Citizenship, Migrant Services and Multicultural Affairs
[2020] FCA 234
At a glance
Source factsCourt
Federal Court of Australia
Decision date
2020-02-28
Before
Finkelstein J, Jagot J
Catchwords
- MIGRATION - effect of quashing the Tribunal's decision by the Federal Court of Australia - application of s 500(6L) of the Migration Act 1958 (Cth) - appropriate order - issue of mandamus - costs
Source
Original judgment source is linked above.
Catchwords
Judgment (2 paragraphs)
- A writ of mandamus issue requiring the Administrative Appeals Tribunal to determine the applicant's application according to law.
- The first respondent pay the applicant's costs of the proceeding as agreed or assessed. Note: Entry of orders is dealt with in Rule 39.32 of the Federal Court Rules 2011.
JAGOT J: 1 On 10 February 2020 I published my reasons for judgment in Ikupu v Minster for Immigration, Citizenship, Migrant Services and Multicultural Affairs [2020] FCA 74. 2 I decided that the Administrative Appeals Tribunal (the Tribunal) had denied the applicant procedural fairness. I made an order quashing the Tribunal's decision. I deferred consideration of making an order in the nature of mandamus so the parties could decide if they wished to be heard in respect of s 500(6L) of the Migration Act 1958 (Cth). Section 500(6L) provides that if the Tribunal has not made a decision within a period of 84 days from notification of the decision under review, the Tribunal is taken to have made a decision affirming the decision under review. 3 The parties filed a joint submission in relation to the operation of s 500(6L). The parties submitted that the Tribunal's decision of 13 August 2019, even though quashed by the Court, is nevertheless a decision for the purposes of s 500(6L) so that the section has no application, with the consequence that an order in the nature of mandamus should be made. 4 The joint submissions at [7] referred to Hall v Minister for Immigration & Multicultural Affairs [2000] FCA 415 ("Hall") in which Finkelstein J said: [30] In my view s 500(6L) will have no application when a matter is remitted to the Tribunal for its reconsideration. Section 500(6L) comes into operation when the Tribunal has not made a decision. For the purposes of that subsection a decision has the same meaning as in the Administrative Appeals Tribunal Act 1975 (Cth): see s 500(7). In that Act a decision is taken to include making or refusing to make an order or determination. The decision of the Tribunal to dismiss the application to review for want of jurisdiction is a decision for the purposes of s 500(6L). Thus the decision under review can no longer be affirmed by default. [31] In the result the Tribunal will not be under any time constraint to deal with the remitted application. This notwithstanding, I assume that the Tribunal will act in accordance with the general policy of the Migration Act and deal with the application as expeditiously as possible. 5 Hall was approved by the Full Federal Court in Somba v Minister for Home Affairs [2019] FCAFC 150 at [36]. The Full Court continued at [38]: …after reinstatement of an application, of the original decision to dismiss, for the purposes of s 500(6L) that decision is one which has in fact been made so s 500(6L)(c) is no longer engaged. We see no cause to read in to s 500(6L) a requirement that the decision be one that has continuing legal effect. 6 The Full Court considered the same issue in Khalil v Minister for Home Affairs [2019] FCAFC 151 saying: [63] In Somba the question was whether a decision to dismiss an application under s 42A of the AAT Act for default in appearance meant that s 500(6L)(c) was no longer engaged, even though the application for review was subsequently reinstated under s 42A(9). In this appeal, the question is whether the Tribunal's decision (made under s 43 of the AAT Act) means that s 500(6L)(c) is no longer engaged, even after the decision is quashed by the issue of a writ of certiorari. [64] In this appeal both the appellant and the Minister submitted that s 500(6L) would have no further application if the court were to quash the Tribunal's decision. It therefore suffices to say that that submission is consistent with the construction of s 500(6L) set out in Somba, and with the approach that Finkelstein J took in Hall v Minister for Immigration & Multicultural Affairs [2000] FCA 415; (2000) 97 FCR 387 at [30]‑[31]. The quashing of the Tribunal's decision here will not result in s 500(6L) being engaged or re‑engaged, and no deemed affirmation of the delegate's decision will arise under that provision. 7 The parties thus submitted that an order in the nature of mandamus directed to the Tribunal should be made. I agree. I record my thanks to the parties and their legal representatives for the joint submission. The order for costs the applicant sought should also be made. I certify that the preceding seven (7) numbered paragraphs are a true copy of the Reasons for Judgment herein of the Honourable Justice Jagot .