Ang Kalatas July 2017 Issue | Page 7

IMMIGRATION: THE LAW ON APPEAL Applicant wins a temporary graduate visa By ATTY. JESSIE ICAO THE dream of staying as a legal resident of Australia can sometimes be shattered by a simple mistake in complying with the legal requirements. This happened to a Filipina nurse from Zamboanga City who studied again in Australia for Bachelor of Nursing deg ree to be a registered nurse in Australia. After completing her Bachelor of Nursing degree in Australia, the applicant applied for temporary residence known as Graduate Temporary (subclass 485) visa. As she was not represented by a lawyer, she applied on her own and uploaded the Australian Federal Police (AFP) certificate which is required at the time of the application. Unbeknown to her, the Department of Immigration and Border Protection required an AFP police certificate which is a complete disclosure. As she had submitted only a standard disclosure AFP Police and not a complete disclosure certificate, her application was refused by the Department. Her dream of staying in Australia was shattered because, if the decision was not overturned, it meant that she had to return to the Philippines and apply offshore as she was barred by section 48 of the Migration Act 1958 which prohibited an applicant from applying for another substantive visa if she had lodged an application on shore which had been denied. www.kalatas.com.au Sometimes the Department of Immigration and Border Protection fails to correctly interpret the legislation, writes JESS ICAO The issue in this case was a legal issue: Whether the law on subclass 485 visa required submission of complete disclosure police certificate not a standard disclosure which was the document submitted by the applicant. Her lawyer successfully appealed her case before the Administrative Appeals Tribunal (Case No. 1707119) on the following grounds: The requirement for a complete disclosure AFP certificate is only an internal policy of the Department as contained in PAM 3 Sche2Visa485 where it says that the ‘only acceptable police certificate for visa purpose will have ‘complete disclosure’ in the heading. The lawyer’s argument was that an internal policy of the Immigration cannot override the enacted law when it says in clause 485.213 of the Migration Regulations 1994 that: When the application was made, it was accompanied by evidence that: (a) the applicant; and (b) each person included in the application who is at least 16; had applied for an Australian Police check during the 12 months immediately before the applicant is made. Clearly, a clear reading of the Regulation did not specify submission of the complete disclosure. The requirement was for an AFP certificate to accompany the application. The Tribunal in its decision in [11] considers that there is merit in each of our submissions. In particular, the Tribunal accepted our submission that the Act requires the applicant to have applied for an AFP National Police Check during the 12 months immediately before she made her application. The legislation does not set out any qualification on the type of National Police Check that has to be applied for. Further, the Tribunal said that the applicant submits, correctly in its view, that PAM 3 does not have the effect or status of legislation and cannot override a clear provision in the Migration Regulations. This is a case where sometimes the Department of Immigration and Border Protection fails to correctly interpret the legislation and the necessity for the losing applicant to seek appropriate legal advice on whether the Department made a mistake in interpreting the legislation which warrants successful appeal. n JESSIE ICAO is a practising solicitor in the State of New South Wales and registered migration agent since 1993 (MARN 9367993). He is admitted as a lawyer in the Philippines. The information provided is of general nature and cannot be relied in its entirety. I suggest that you consult a registered migration agent or refer to the relevant law. AK NewsMagazine, Vol 7 No 10 | JULY 2017 07