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 22 May 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. |