© 2026 Zoe. All rights reserved.
Zoe is a legal information platform. Always consult the Federal Register of Legislation for authoritative text.
[2004] FCA 57
Federal Court of Australia
2004-02-06
Tamberlin J
Original judgment source is linked above.
REASONS FOR JUDGMENT 1 The applicants are a wife, husband and daughter who arrived in Australia on 25 March 1999. They lodged an application for a protection visa under the Migration Act 1958 (Cth) ("the Act") on 15 April 1999. On 29 June 1999, a Ministerial delegate refused to grant a protection visa. On 29 July 1999, the applicants applied for review by the Refugee Review Tribunal ("the RRT"). 2 On 14 March 2002, the RRT accepted that the applicant husband had a well-founded fear of persecution on religious grounds if returned to Russia, and that the wife had a well-found fear of persecution based on the religious beliefs that would be imputed to her. That determination is not challenged. They are therefore "refugees" within the Convention definition. However, the RRT found that Australia would not be in breach of its protection obligations to the applicants under the Convention if it expelled them to Israel, because the Israeli "Law of Return" renders Israel a safe "third country" for the applicants, within the principles stated by the Full Court in Minister for Immigration and Multicultural Affairs v Thiyagarajah (1997) 80 FCR 543 ("Thiyagarajah"), which has been followed by subsequent Full Court judgments. These are summarised by the Full Court in NAGV v Minister for Immigration and Multicultural and Indigenous Affairs (2003) 202 ALR 1 ("NAGV") at [2], [66]-[67] and in NAEN v Minister for Immigration and Multicultural and Indigenous Affairs [2003] FCA 216 at [40]-[53]. The present application is brought from the RRT decision and was filed on 8 May 2003. 3 The facts are brief and are not in dispute. The applicants arrived in Australia on 25 March 1999, on passports of the Russian Federation. The RRT found that they were nationals of that country, and it was against the Russian Federation that their claims were assessed. The RRT accepted that the husband and wife had well-founded fears of persecution for Convention reasons. In its Reasons for Decision, the RRT applied the reasoning of the Full Court in Thiyagarajah. It held thatAustralia does not have protection obligations to a person who has been accorded effective protection in a third country, which is to say that, as a matter of practical reality and fact, they are likely to be permitted to enter and live in that country, without being at risk of being returned to their original country. The RRT held that in such circumstances, it would be consistent with Australia's obligations under Article 33 of the Convention, to send the applicant to that third country without considering whether he or she is a refugee: see also Minister for Immigration & Multicultural Affairs v Al-Sallal (1999) 94 FCR 549) ("Al Sallal").
submissions of applicantS 4 The applicants advance two submissions. The first is that the RRT erred in relying on what has become known as the doctrine of "effective protection", which has been referred to in Thiyagarajah and subsequent cases. They point out that Thiyagarajah was heavily criticised by the Full Court in NAGV, and its reasoning was found to be erroneous, although the decision was not overruled. The applicants also refer to the recent decision of the Full Court in WAGH v Minister for Immigration and Multicultural and Indigenous Affairs [2003] FCAFC 194 ("WAGH"), particularly at [37]. The applicants submit that the doctrine of effective protection is no answer to the claim that Australia has protection obligations where a person is found to be a "refugee" within the meaning of the Convention and Protocol. They argue that, since they have been found to have a well-founded fear of persecution for Convention reasons in their country of nationality, Australia is obliged under Article 33 of the Convention to protect them from return to a place where their life or freedom is under threat, or refoulement. 5 The applicants' second submission is that even if Israel's Law of Return relieves Australia of its protection obligations towards a Jewish refugee present in Australian territory, there are serious doubts as to whether this Law of Return should be recognised as valid and binding legislation for reasons of Australian public policy. It is said that the Law of Return, as summarised, provides virtually automatic right of entry to Israel, and citizenship of that county, only to persons of Jewish ethnicity or religion. The submission is that, on its face, such a law institutionalises racial discrimination within the meaning of Article 1 of the International Convention on the Elimination of All Forms of Racial Discrimination opened for signature 21 December 1965. UNTS 195 (entered into force 4 January 1969), ratified by Australia by operation of s 3(1) of the Racial Discrimination Act 1975 (Cth), because it does not extend the right of entry to persons of other ethnicity or religious belief. More specifically, the submission is that the RRT should have addressed the question as to whether the prima facie racial discrimination inherent in the Israeli Law of Return meant that reliance on it by Australia would be repugnant to basic values enshrined in Australia law by anti-discrimination legislation. 6 For each of the above reasons, it is submitted that the decision of the RRT should be set aside.
Thiyagarajah 7 The facts in Thiyagarajah were that the applicant was a Sri Lankan national who arrived in France in May 1985. France granted him refugee status in November 1988. He entered Australia on 12 December 1994, and, in April 1995, applied for protection visas for himself, his wife and child. A Ministerial delegate determined that he was not entitled to a protection visa on the basis that he fell within Article 1E of the Convention Relating to the Status of Refugees 1951 189 UNTS 150, entered into force 22 April 1954, as amended by the Protocol Relating to the Status of Refugees, 606 UNTS 267, entered into force 4 October 1967 ("the Convention"). Article 1E provides that: "This Convention shall not apply to a person who is recognised by the competent authorities of the country in which he has taken residence as having the rights and obligations which are attached to the possession of the nationality of that country." 8 The RRT affirmed the decision of the delegate. An application was made to this Court for review. The primary Judge set aside the RRT decision on the ground that Article IE did not apply to Mr Thiyagarajah because refugees in France were subject to restrictions, including being prohibited from working in the French Public Service. 9 On appeal to the Full Court, the issue was whether a person who has effective protection in another country, including the right to reside, enter and re-enter, to work in most occupations and apply for citizenship, and who has established residence in that country, is entitled to claim protection from other contracting states under the Convention. In addition to Article 1E, the Full Court in Thiyagarajah directed attention to Article 33 of the Convention which provides: "Article 33 Prohibition of expulsion or return (refoulement)
I certify that the preceding twenty-six (26) numbered paragraphs are a true copy of the Reasons for Judgment herein of the Honourable Justice Tamberlin.
Solicitor for the Respondent: Australian Government Solicitor
NAPI
Minister for Immigration and Multicultural and Indigenous Affairs