Title	Submission by the United Nations High Commissioner for Refugees in the case AS (Afghanistan) v. Secretary of State for the Home Department
Publisher	UN High Commissioner for Refugees (UNHCR)
Publication Date	7 March 2019
Country	Afghanistan | United Kingdom of Great Britain and Northern Ireland
Topics	Internal flight alternative (IFA) / Internal relocation alternative (IRA) / Internal protection alternative (IPA)
Citation / Document Symbol	2018/1968
Related Document(s)	AS (Safety of Kabul) Afghanistan CG [2018] UKUT 00118 (IAC)  |  AS (AFGHANISTAN) (Appellant) - and - SECRETARY OF STATE FOR THE HOME DEPARTMENT (Respondent) - and - THE UNITED NATIONS HIGH COMMISSIONER FOR REFUGEES (Intervener) [2019] EWCA Civ 873
Cite as	UN High Commissioner for Refugees (UNHCR), Submission by the United Nations High Commissioner for Refugees in the case AS (Afghanistan) v. Secretary of State for the Home Department, 7 March 2019, 2018/1968, available at: https://www.refworld.org/docid/5c91140b4.html [accessed 8 June 2023]
Comments	UNHCR’s core submission is as follows. The correct approach when assessing the reasonableness of a proposed internal relocation, flight or protection alternative (“IFA”) is to carry out a single, holistic assessment which focuses upon the circumstances of the individual. That assessment: 2.1 may, as one factor, consider what is ‘a relatively normal life’ in the context of the country concerned; but 2.2 must consider the conditions in the place of relocation against certain objective ‘baseline standards’; and 2.3 must consider the impact of the proposed relocation on the particular individual, having regard to that individual’s characteristics, personal circumstances and past experiences.