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[2002] AATA 1277
respondent. The Tribunal affirmed the decision refusing renewal of the applicant's Australian passport.
The Tribunal treated Mrs Tripp's application for South African naturalisation as the legally relevant act. It accepted that she wanted citizenship so she could vote in a referendum, but considered that this did not change the purpose of the application itself: to acquire South African citizenship. Since the citizenship was acquired, the Tribunal found that the then-applicable s 17 automatically ended her Australian citizenship. It therefore upheld the refusal to renew her Australian passport, which could be issued only to Australian citizens.
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2,589 words · generated 01/10/2026
The Administrative Appeals Tribunal reviewed a decision refusing to renew Margaret Ann Tripp's Australian passport. Senior Member M J Sassella heard the matter in Sydney on 5 November 2002 and delivered the decision on 10 December 2002. The Tribunal affirmed the refusal [1–2, 33].
3 cited instruments linked from this judgment.
Mrs Tripp was born in Manly, Sydney, on 17 October 1931 [3]. She moved to South Africa in 1955, married there, and remained living there. She became a permanent resident of South Africa in 1962 [4]. Her daughter and grandchildren lived in Sydney, and she usually visited them annually [5].
The central event was her decision to become a South African citizen. In 1991, as South Africa prepared for a referendum concerning continuation of the reform process, Mrs Tripp and her husband decided that they wanted to vote. The Tribunal recorded that naturalisation was necessary to vote [18–19]. Mrs Tripp applied for naturalisation and became a South African citizen on 17 March 1992 [6, 20–21]. She said she understood that applying would make her a South African citizen, but did not know that acquiring that citizenship would cause her to lose Australian citizenship [20].
The passport issue arose years later. Mrs Tripp obtained a South African passport in 1996, which she found made leaving and re-entering South Africa easier [7]. When her Australian passport approached expiry in 1999, she applied for renewal and disclosed that she was a South African citizen. She was told that she could not have an Australian passport because she held a South African passport [8]. In April 1999, she applied to resume Australian citizenship under s 23AA of the Australian Citizenship Act 1948 [9]. The Tribunal's reasons recount the subsequent refusal of passport renewal and the internal review that affirmed it [10–13].
The Tribunal had to decide whether Mrs Tripp was an Australian citizen for passport purposes. The statutory path was linked: s 7(1) of the Passports Act 1938 permitted the Minister or an authorised officer to issue Australian passports to Australian citizens, while s 5(1) defined that status by reference to the Australian Citizenship Act 1948 [14–15]. The critical question was whether s 17 of the citizenship Act had already caused her Australian citizenship to cease when she acquired South African nationality.
The Tribunal's key reasoning concerned how to identify the relevant “act or thing” and its “sole or dominant purpose” under s 17(1). The provision, in the version applicable before 4 April 2002 and reproduced in the reasons, applied to an Australian citizen aged at least 18 who did an act or thing whose sole or dominant purpose and effect were to acquire the nationality or citizenship of a foreign country. On acquisition, the person ceased to be an Australian citizen [16–17].
Mrs Tripp's explanation focused on why she wanted South African citizenship. She wanted to participate in the referendum and believed voting mattered to South Africa's future. She did not intend to give up Australian citizenship; she said she was told by a South African official that naturalisation would not cause that loss [19–21, 25]. Her representative relied on Gugerli and argued that the purpose of the relevant act was voting, while acquiring South African citizenship was the act's effect [22–24].
The respondent's argument focused more narrowly on the immediate act. It submitted that the relevant act was applying for naturalisation, an application Mrs Tripp knew would make her a South African citizen. On that view, the desire to vote explained her motive for acquiring citizenship, rather than changing the purpose of the naturalisation application itself [27–29]. The Tribunal accepted that argument as the better one, based on its reading of Gugerli [31].
The Tribunal understood Gugerli to distinguish acquiring foreign citizenship from confirming an existing foreign citizenship status. It said the person in Gugerli applied to Swiss authorities to have her Swiss citizenship recognised and was not seeking to acquire Swiss nationality. The Tribunal therefore treated that case as different from Mrs Tripp's situation: her naturalisation application was intended to change her status by making her a South African citizen [24, 31].
The reasoning depends on separating an immediate act from the broader aim that explains why a person undertakes it. The Tribunal treated Mrs Tripp's application for naturalisation as the act whose purpose had to be assessed. It regarded becoming a South African citizen as the purpose of that application, while voting was the later objective that the citizenship enabled. The Tribunal described citizenship as a platform for achieving that later aim [31]. In its view, the fact that the applicant's ultimate purpose was political participation did not displace the purpose of the act of applying for citizenship.
The Tribunal also noted that Mrs Tripp's earlier written submissions described her purpose in different ways. One solicitor's letter said the purpose was to acquire dual Australian and South African citizenship; a later letter said the purpose was not to acquire foreign nationality, but to become eligible to vote [26]. The Tribunal did not treat that inconsistency as a separate legal test. Its reasoning instead turned on the character of the act and the distinction drawn from Gugerli [31].
Having found the requirements of s 17 satisfied, the Tribunal treated cessation of citizenship as automatic. It had already noted that s 17 operated without a decision-maker needing to take a separate step once the statutory terms were met [17]. Because Mrs Tripp was no longer an Australian citizen, she did not meet the citizenship condition for a passport under the Passports Act provisions quoted in the decision. The Tribunal consequently affirmed the refusal [14–17, 32–33].
The decision describes the relevant statutory position at the time of the naturalisation and passport events. In particular, it reproduces s 17 of the Australian Citizenship Act 1948 as it stood before 4 April 2002 [16]. The text required both a specified purpose and a specified effect: the act's sole or dominant purpose had to be to acquire foreign nationality, and the act had to have that effect. The provision stated that citizenship ceased “upon that acquisition” and excluded an act of marriage [16].
The Tribunal characterised the statutory consequence as automatic. Its explanation was that once the conditions in s 17 were met, the affected person's Australian citizenship ended without necessary intervention by a decision-maker [17]. In this case, the Tribunal found the relevant acquisition had occurred in 1992 and considered the later passport application against that consequence [6, 31–32].
The decision also sets out the passport rules. Section 7(1) permitted issue of an Australian passport to Australian citizens, subject to regulations. Section 5(1) referred to the meaning of Australian citizen under the citizenship Act [14–15]. The Tribunal's conclusion followed from the interaction of those provisions with its finding under s 17.
The reasons do not set out or analyse the content of any amendment taking effect on or after 4 April 2002. Nor do they provide a comprehensive account of the later law governing dual citizenship or passport eligibility. The “after” position that can safely be stated from this decision is limited to its disposition: the Tribunal affirmed the passport refusal because it found that Mrs Tripp's Australian citizenship had ceased under the version of s 17 it applied [16, 32–33]. The judgment alone does not establish how later legislative changes affected other cases.
As a source of precedent, this is an AAT decision applying a Federal Court authority, not a judgment of the Federal Court itself. Its reasons express the Tribunal's interpretation of Gugerli for the purpose of deciding Mrs Tripp's review. The decision identifies Gugerli as the authority underpinning its approach and distinguishes it on the difference between acquiring citizenship and confirming an existing status [23–24, 31]. The extract does not establish any broader binding status for the Tribunal's reasoning.
At [16], the decision reproduces the operative elements of s 17: an adult Australian citizen must do an act or thing with the sole or dominant purpose of acquiring foreign citizenship, and that act must have the effect of acquiring it. In plain English, the provision did not make every acquisition of another nationality sufficient by itself. The purpose of the relevant act mattered as well as its effect.
At [17], the Tribunal says the statutory loss occurred automatically once s 17's terms were met. In plain English, the Tribunal did not consider that a separate official decision was needed to end citizenship under that provision.
At [20], Mrs Tripp's account separates what she knew from what she did not know. She knew naturalisation would make her a South African citizen. She said she did not know this would end her Australian citizenship. The Tribunal's decision therefore distinguishes her awareness of the foreign citizenship consequence from her understanding of the Australian citizenship consequence.
At [23–24], the decision recounts the applicant's reliance on Gugerli. As presented in the reasons, Gugerli treated “purpose” as directed to the factors that influenced the person to do the act, while also distinguishing purpose from motive. The Tribunal then records the respondent's account that the Gugerli applicant was confirming Swiss citizenship she already understood herself to possess, rather than acquiring it.
At [28], the respondent's submission was that the nature of the act itself said much about its purpose. That was a submission, not a free-standing finding at that point in the reasons. The Tribunal later accepted the respondent's analysis as the better argument [31].
The decisive application appears at [31]: the Tribunal considered that Mrs Tripp sought naturalisation to become a South African citizen, “albeit so that she could later vote in the referendum.” In plain English, becoming a citizen was treated as the direct purpose of the naturalisation application, while voting was treated as the later objective enabled by citizenship.
At [32–33], the Tribunal moves from citizenship to passport eligibility. It found that the acquisition of South African citizenship had annulled Mrs Tripp's Australian citizenship and, because a passport could be issued only to an Australian citizen, affirmed the refusal.
The reasoning is most directly relevant to a fact pattern involving an adult Australian citizen who deliberately applies for, and acquires, another country's nationality through a process that changes their citizenship status. The central feature is not merely that the person later holds a foreign passport. It is the relationship the Tribunal identified between the act of applying for naturalisation, the purpose of that act, and the actual acquisition of foreign citizenship [7, 16, 31].
The decision also speaks to situations where the person's wider reason for acquiring foreign citizenship is a further benefit, such as eligibility to vote. The Tribunal treated that type of later objective as distinct from the direct purpose of the application that secured citizenship [19, 28–31]. That part of the reasoning would be pertinent where the applicant knows that naturalisation will confer citizenship, even if the person is pursuing it to access some other activity.
The decision draws a contrasting boundary around a person who applies to have an existing foreign citizenship recognised rather than to acquire a new one. The Tribunal understood Gugerli to involve confirmation of Swiss status, and relied on that difference to distinguish the precedent [24, 31]. The distinction matters to the reasoning because the Tribunal did not treat a request to confirm an existing status as equivalent to the act of applying for naturalisation to obtain a new status.
The case is also relevant to passport decisions where eligibility depends on citizenship under the legislation. The statutory structure described in the reasons ties passport issue to Australian citizenship [14–15]. A citizenship question can therefore determine the passport outcome, as it did here [32–33].
The reasons do not decide every possible variation. For example, the Tribunal records, but does not determine, a hypothetical in which voting itself automatically causes the acquisition of foreign citizenship [29]. It also does not decide the effect of a naturalisation process where the person did not know it would confer foreign citizenship, or where the process had a different legal effect. Those scenarios cannot be resolved simply by extending the result beyond the facts and statutory text addressed in this decision.
The supplied judgment contains no discussion of later judicial treatment of Tripp. It was decided on 10 December 2002 and cites Gugerli as its relevant Federal Court authority [23–24, 31]. The judgment does not identify any later case that followed, distinguished, criticised, affirmed, or reversed the Tribunal's decision.
Accordingly, no claim about later treatment can be grounded in this judgment alone. The decision does show how this Tribunal used Gugerli at the time: it understood Gugerli as distinguishing an application to confirm an existing citizenship from an application intended to acquire citizenship, and applied that distinction to Mrs Tripp's naturalisation [24, 31]. That is the available precedent relationship from the text, not evidence of subsequent appellate review or later acceptance by other courts.
For legal research, the key source limitation is that the decision itself offers only a short account of Gugerli and no later authorities. Any assessment of whether the approach remained current would require sources beyond this judgment. Nothing in the supplied reasons supports a conclusion about the subsequent legislative history or the later treatment of either case.
Several limits remain visible from the decision. First, although the Tribunal adopts a distinction between “purpose” and a person's ultimate objective, it does not supply an exhaustive method for identifying the relevant act where a sequence of acts is involved. It identifies the naturalisation application as the relevant act here, and voting as the later aim [27–31]. The reasons do not determine how the analysis would operate if the legal acquisition occurred through a different step or automatically as a consequence of some other act.
Second, the decision does not decide the hypothetical discussed by the respondent: a person votes in a foreign referendum and thereby automatically acquires foreign citizenship [29]. The Tribunal uses that example to illustrate the parties' competing approaches, but its own disposition concerns an application for naturalisation followed by voting.
Third, the reasons do not resolve how much knowledge about the legal consequences is necessary for the purpose test. Mrs Tripp knew the application would result in South African citizenship but said she did not know that this would end her Australian citizenship [20]. The Tribunal's reasoning focused on the purpose and effect of the naturalisation application; it did not separately decide that awareness of the Australian-law consequence was an element of s 17 [16, 31–32].
Fourth, the judgment identifies the statutory version as the one before 4 April 2002 but does not explain the changes made from that date or their effect on other situations [16]. The result therefore needs to be read with care outside the statutory setting described in the reasons.
Finally, the decision does not discuss the legal effect or outcome of Mrs Tripp's 1999 application to resume Australian citizenship under s 23AA. It records that she made that application [9], but its final reasoning proceeds on the basis that she had lost citizenship and considers the passport refusal on that basis [31–33]. The judgment does not set out a separate determination of the resumption application.
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DECISION AND REASONS FOR DECISION [2002] AATA 1277
Decision The tribunal affirms the decision under review.
AUSTRALIAN PASSPORT - refusal of grant of passport - passport can be granted only to Australian citizen - applicant was South African citizen - whether applicant's application for South African naturalisation caused cessation of Australian citizenship - whether act of seeking South African naturalisation was an act or thing done with the sole or dominant purpose of acquiring foreign nationality
Passports Act 1938 ss 5(1) ("Australian citizen"), 7(1)
Minister for Immigration, Local Government and Ethnic Affairs v Gugerli [1992] FCA 238; (1992) 36 FCR 68
1. On 4 January 2002 Margaret Ann Tripp ("the applicant") applied to the Administrative Appeals Tribunal ("the tribunal") for review of a decision by a person authorised ("an authorised officer") by the Minister for Foreign Affairs and Trade ("the respondent") made on 22 June 2001 (T6). This decision was affirmed by another authorised officer of the respondent on 10 December 2001 (T17). The decision under review was to reject the applicant's application for renewal of her Australian passport.
2. The tribunal convened a hearing in this matter in Sydney on 5 November 2002. Mr Justin Smith of counsel represented the applicant. Mr B Dubé of the Australian Government Solicitor's office in the ACT represented the respondent. There was oral evidence from the applicant by telephone from South Africa. The tribunal took into evidence the following documents:
Exhibit TD1 - Section 37 Statement and associated documents (exhibits T1 - T18) provided by the respondent.
Exhibit A1 - Applicant's statement of facts and contentions, undated.
Exhibit A2 - Statement by applicant, 30 October 2002.
Exhibit R1 - Respondent's statement of facts and contentions, 12 July 2002.
Exhibit R2 - Sample of South African application for certificate of naturalisation.
FINDINGS ON MATERIAL QUESTIONS OF FACT WITH REFERENCE TO THE EVIDENCE AND OTHER MATERIAL IN SUPPORT OF THOSE FINDINGS
3. Mrs Tripp was born in Manly, the Sydney suburb, on 17 October 1931 (ex A2).
4. In 1955 Mrs Tripp became resident in South Africa (ex A2). She married Michael Tripp in South Africa in 1955 and has lived with him there ever since. On 23 November 1962 Mrs Tripp was registered as a permanent resident of South Africa (ex A2).
5. Mrs Tripp has a daughter who lives in Sydney (ex A2). That daughter in turn has two children. Mrs Tripp usually visits Sydney on an annual basis and stays for one to two months. She sees these relatives on these trips to Australia.
6. On 17 March 1992 Mrs Tripp became a citizen of the Republic of South Africa (ex R1).
7. On 23 August 1996 Mrs Tripp was issued with a South African passport (ex A2). She found that a South African passport facilitated the leaving from and re-entering into South Africa.
8. In 1999 Mrs Tripp's Australian passport was reaching its expiry date. In March 1999 Mrs Tripp lodged an application for renewal of her Australian passport (ex A2). She told a departmental officer that she was a South African citizen. In that same month a person from the Australian Consulate in Capetown telephoned Mrs Tripp and told her that she could not have an Australian passport because she had a South African passport.
9. On 6 April 1999 Mrs Tripp completed and submitted to the Australian High Commission an application to resume her Australian citizenship in accordance with s 23AA of the Australian Citizenship Act 1948 ("the ACA").
10. On 26 April 2001 the applicant asked that the decision to reject her application for renewal of her passport be reviewed (T4).
11. On 22 June 2001 an authorised officer determined that Mrs Tripp's application for renewal of her Australian passport must be refused on the basis that she was not an Australian citizen (T6).
12. On 13 July 2001 the applicant sought a review of that decision in accordance with s 11A(1) of the Passports Act 1938 ("the Act") (T7).
13. On 10 December 2001 an authorised officer affirmed the decision dated 22 June 2001 (T17).
14. Several legislative provisions interact. First there is s 7(1) of the Act:
7(1) Subject to the regulations, the Minister or an officer authorised in that behalf by the Minister may issue Australian passports to Australian citizens.
a person who is an Australian citizen within the meaning of the Australian Citizenship Act 1948-1973.
16. Section 17 of the ACA as it was before 4 April 2002 read as follows:
Loss of citizenship on acquisition of another nationality
17 (1) A person, being an Australian citizen who has attained the age of 18 years, who does any act or thing:
is to acquire the nationality or citizenship of a foreign country, shall, upon that acquisition, cease to be an Australian citizen.
(2) Subsection (1) does not apply in relation to an act of marriage.
17. Section 17 of the ACA operated automatically. Once the terms of s 17 were met the affected person automatically lost Australian citizenship without any necessary intervention by a decision-maker.
18. The applicant explained her decision to seek South African citizenship by referring to South African political developments. In short, after decades of repressive and racist government by the National Party, that government announced in 1991 that it intended to hold a referendum in 1992 asking citizens of South Africa to answer whether they supported continuation of the reform process that the State President began on 2 February 1990 and which was aimed at a new "constitution by negotiation" (ex A2).
19. Mrs Tripp saw a positive outcome of the 1992 referendum as crucial for the future viability of South Africa (ex A2). There was great pressure on people in South Africa to register to vote. A person had to be naturalised in order to vote. Mr and Mrs Tripp decided during 1991 that they should vote in the referendum and decided to become naturalised in South Africa in order to be able to do so.
20. Mrs Tripp completed the required forms and presented them in person at the South African Department of Home Affairs. She overheard a South African government official inform a German citizen that, if he proceeded with South African nationalisation, he would lose his German citizenship. The German citizen decided to proceed no further and left. Mrs Tripp asked the same official if she would lose Australian citizenship if she proceeded with naturalisation. The official told her that she would not. She proceeded with naturalisation. She wrote in ex A2:
"I knew that the effect of making the application was that I would become a citizen of South Africa, however the reason why I made the application was because of my desire to vote in the upcoming referendum. What I did not know was that by becoming a South African citizen I would lose my Australian citizenship."
21. Mrs Tripp confirmed this material in her oral evidence. In that evidence Mrs Tripp said that she received her certificate of South African naturalisation, that she registered to vote in the referendum and did vote in the referendum.
22. Mr Smith, for Mrs Tripp argued as follows suggesting that Mrs Tripp had not lost her citizenship by means of s 17 of the ACA. Section 17(1), he said, contains two paragraphs. One relates to purpose. The other relates to effect. The sole or dominant purpose of the act here was to vote in the referendum. The effect of the act was to acquire South African citizenship.
23. Mr Smith referred to the decision in Minister for Immigration, Local Government and Ethnic Affairs v Gugerli [1992] FCA 238; (1992) 36 FCR 68 in which Davies J addressed the terms of s 17 of the ACA and said at page 73:
"As can be seen, the test looks at the factors which influenced the mind of the person doing the act, factors which actuated the carrying out of the step ... In his oft-cited judgment in Cox v Smail [1912] VicLawRp 50; [1912] VLR 274, Cussen J analysed the assessment of such factors. His Honour referred (at 279) inter alia to 'advertence, expectation, and desire' as matters to be taken into account in ascertaining the factors influencing the decision to act and the weight to be given to them.
"That such an approach should be adopted in the interpretation of s 17 is, I think, clear from the fact that the element of purpose was deliberately introduced into s17 of the Australian Citizenship Amendment Act 1984 and from the terms of the section which distinguish between the purpose for which the act is done and the effect thereof.
"Although the 'purpose' in the sense in which the word is used in s 17 looks to a state of mind, it is not to be equated in all respects with motive. If a person's sole or dominant purpose in doing an act is to acquire the citizenship of another country, it matters not why the person wishes to acquire the citizenship or what use he or she will make of it."
24. As the respondent said in its statement of facts and contentions, Davies J's conclusion was that the act of the person in Gugerli (above) was to apply to Swiss authorities for recognition of her Swiss citizenship. She understood herself to already be a Swiss citizen. Her sole or dominant purpose was not to acquire Swiss nationality. Her act in making application did not, therefore, cause the cessation of her Australian citizenship.
25. Mr Smith emphasised the applicant's intention at all times not to lose her Australian citizenship.
26. The tribunal noted, in fact, that the papers presented for the applicant suggested two different versions of the dominant purpose. On 26 April 2001 the applicant's solicitor wrote to the Department of Foreign Affairs and Trade (T4/10) stating that "Mrs Tripp's 'sole or dominant purpose' of [adopting South African citizenship] was to acquire dual citizenship of Australia and South Africa" [applicant's emphasis]. Later, however, on 13 July 2001 the applicant's solicitor wrote (T7/16), "the sole or dominant purpose of her application for South African citizenship was not to acquire the nationality or citizenship of a foreign country, but rather to be eligible to vote in South Africa" [applicant's emphasis].
27. The gist of the respondent's case was expressed in paragraphs 27-30 of its statement of facts and contentions:
27. The applicant contends that her sole or dominant purpose was to be able to vote rather than obtain citizenship.
28. The applicant's submissions on the dominant purpose of her actions disregard the nature of the 'act or thing' done. The evidence of the applicant is clear that her motive in applying for South African citizenship was to enable her to vote in the referendum. It is also clear that the applicant believed that she would retain Australian citizenship on acquiring South African citizenship.
29. However, it is equally clear, from the applicant's evidence, that she was aware that in applying for South African naturalisation she would become a South African citizen.
30. If the 'act' of the applicant had been to vote in the referendum, whereby the effect of which was to also acquire South African citizenship, the applicant would be able to distinguish the statement in Gugerli regarding motive. However, because the initial act was solely application to acquire South African citizenship, the applicant's desire to vote in the referendum, can only be construed as her motive for acquiring citizenship rather than the dominant purpose of the 'act' she undertook. The 'purpose' of the applicant's naturalisation application was solely to become a South African citizen.
28. Effectively the respondent's argument here was that the act done, in itself, says much about the sole or dominant purpose. The very act was the acquisition of South African citizenship. The applicant had a purpose of achieving this end when she applied for naturalisation. She intended to acquire a change of citizenship status. This was what was described at the hearing as a "hurdle act". The "ultimate act" was to vote.
29. Mr Dubé contrasted the situation with one where a person voted in a referendum in a foreign country and in so doing automatically acquired foreign citizenship. Section 17 of the ACA would not cause the cessation of Australian citizenship in that case.
30. Mr Smith countered these submissions by arguing that, while some focus on the "act or thing" might be justified, that inquiry cannot occur without consideration of the purpose of the doing of the act or thing. That consideration must, in turn, take account of the factors surrounding it. He said that the surrounding circumstances in Mrs Tripp's case were so overwhelming and so central that they drove the dominant purpose.
31. The tribunal has concluded that Mr Dubé had the better of the arguments in this application, based on the Federal Court authority in Gugerli (above). The tribunal understands Davies J in Gugerli (above) to have taken the view that a person who does an act or thing, such as applying for foreign nationality, citizenship or naturalisation, with a view to attaining foreign nationality, albeit in order to use that as a platform for achieving a later aim, has done an act or thing for the sole or dominant purpose of acquiring the nationality or citizenship of a foreign country. That, in the tribunal's view, is what occurred here. Mrs Tripp sought South African naturalisation in order to become a South African citizen, albeit so that she could later vote in the referendum. She did an act or thing that had the purpose of changing her South African citizenship status. The case is distinguishable from Gugerli (above) where the individual did an act for the purpose of confirming her status as a citizen of Switzerland. In that case the purpose was not to change foreign citizenship status.
32. While the tribunal respects Mrs Tripp's reasons for seeking South African naturalisation, it has found, in accordance with Federal Court authority, that the purpose at law of her seeking South African naturalisation was to acquire the nationality or citizenship of a foreign country. This had the effect of annulling her Australian citizenship. As Mrs Tripp had lost her Australian citizenship, the respondent acted properly in rejecting her application for a passport.
33. The tribunal affirms the decision under review.
I certify that the 33 preceding paragraphs are a true copy of the reasons for the decision herein of Mr M J Sassella, Senior Member
Signed: .....................................................................................
Solicitor for the applicant Aitken McLachlan & Thorpe, Solicitors
Solicitor for the respondent Australian Government Solicitor
Minister for Immigration, Local Government and Ethnic Affairs
Gugerli
(1992) 36 FCR 68
The Tribunal affirmed the decision refusing renewal of the applicant's Australian passport.