International Protection Office Failed Explicitly to Address the Applicant’s Sexual Orientation

Mark Tottenham BL, Decisis

October 1, 2024

M.M v Chief International Protection Officer [2022] IECA 226 (Court of Appeal, Ní Raifeartaigh J, 14 October 2022)

Court of Appeal allowed appeal from the refusal of judicial review by the High Court, and determined that a decision by the International Protection Office (IPO) must be reconsidered due to the absence of explicit findings on a core issue, namely the appellant's claim of lesbian sexual orientation. The court found that the IPO's failure to directly address and make clear findings on the appellant's sexual orientation and the associated risk of persecution if returned to her country of origin was an error. Consequently, the IPO's decision and the subsequent Ministerial ‘permission to remain’ process are to be re-evaluated, focusing on the appellant’s sexual orientation and potential risk to personal safety.

International Protection Office (IPO) – sexual orientation – lesbian – persecution – refoulement – Zimbabwe – Court of Appeal – asylum seeker – international protection claim – credibility assessment – country of origin information – statutory interpretation – independent decision-making – procedural justice – remittal for reconsideration

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