Post-Palmer reform of the Department of Immigration

by David Manne, Co-ordinator of the Refugee & Immigration Legal Centre, for the Inaugural Australian CPD Immigration Law Conference.

Presented 9 February 2007

 

It’s a real pleasure to be speaking today with the head of the Department of Immigration and Citizenship (“the Department”), Andrew Metcalfe; and on an issue which lies at the heart of the current state of play of Australian Immigration – the reform process triggered by the Mick Palmer and Neil Comrie reports into the Cornelia Rau and Vivien Solon scandals. May I first take this opportunity to express our sincere gratitude to Andrew for accepting the invitation to speak at this inaugural Australian CPD Immigration Law Conference, and to note that it is the many important actions like this which provide tangible proof that reform priorities, such as improved stakeholder engagement, are being implemented and that leadership is coming from the front.

My focus this morning will be on the so-called ‘post-Palmer reform process’ and its progress – and in particular, on how the Department is progressing with this - rather than focusing on Government policy.

Thus, since the Palmer and Comrie reports, to what extent has there been significant reform within the Department in areas identified by Palmer; and, are there areas in the reform process which have been deficient?

While it was Government policy to accept, comprehensively, the recommendations made by Palmer and Comrie, reform of Government policy itself was clearly outside the Palmer and Comrie briefs. And while many Government policies, especially concerning human rights practices rightly remain of profound and passionate concern to many, I won’t today be addressing these matters.

That means, for example, that I won’t be addressing in any detail a number of Government policies which amount to one of the toughest, most legally controversial, hostile and extensive anti-asylum systems in the Western world, key features of which continue to be:

• mandatory, indefinite, non-reviewable detention;
• Temporary Protection and Humanitarian Visas;
• ‘excision’ of Australian territory to preclude people seeking asylum in Australia at all;
• naval repulsion of asylum seekers arriving by boat; and
• the ‘Pacific Solution’ and offshore processing of asylum claims.

While such polices were not part of the Palmer brief, and while we can’t fix the legislation if the Government won’t shift and while it would be unreasonable to attribute responsibility to the Department for failures on this front, these and other controversial areas of policy are far from irrelevant to the reform process. In fact, they provide crucial context. I will return to this issue shortly.

So now let’s turn now to the Palmer report and the ensuing reform process.

It’s a chance to take stock, and recall where we have come from in recent times.

During 2005, the shocking and tragic circumstances of the Cornelia Rau and Vivian Solon cases awakened in Australians a recognition of the scandalous abuse and cruel indifference which the Immigration system was perpetuating on innocent and vulnerable people, including asylum seekers.

A number of significant developments flowed from this. The Government rejected credible calls for a Royal Commission and instead established the Palmer Inquiry, amidst much scepticism as to whether Mick Palmer could and would do the job required. Mick Palmer’s report surprised many sceptics – it ultimately made findings constituting one of the most devastating indictments of a major government department in Australia’s history.

Two of the key problem areas of Departmental practice which Palmer identified centered on:

(1) Culture – that is, a “culture that is overly self-protective and defensive, a culture largely unwilling to challenge norms or to engage in genuine self-criticism or analysis”; and

(2) A systemic approach described as “process rich and outcomes poor” – that is, “an entrenched culture fixed on process and apparently oblivious to the outcomes being achieved.”

It was largely in response to Palmer report - and the Petro Geogiou sponsored Bills and the compromise deal subsequently struck with the Prime Minister, - that a process of ‘wide-ranging, systemic reform’ of the Department, was promised and commenced in the first half of 2005.

For those familiar with the workings of the Department, including those here today, these findings came as no surprise. Rather, they resonated loudly, if not painfully.

So what’s been achieved since then? To what extent has there been significant reform within the Department in the areas identified by Palmer; and, are there are areas in the reform process which have been deficient?

In addressing these issues, I do not propose to offer an academic study of the Palmer package or a systematic scorecard in its totality. Rather, I want give an impressionistic sketch of some key areas and themes from the viewpoint of a legal practitioner and advocate heading a leading agency whose daily work includes dealing directly with some of the most complex and difficult interactions with the Department for clients and stakeholders.

I think a useful way to address the question of progress is to compare some examples of problem areas in Departmental operation before and after the Palmer report, under two broad categories:

(1) treatment of clients; and

(2) treatment of stakeholders,

with the emphasis on treatment of clients; that is, people – who must always matter most in the Immigration administration. I acknowledge that the Secretary and his Department have formally – and rightly - placed this issue front and center of the reform process agenda and the Department’s ‘business’.

(1) Treatment of clients

(a) Processing of boat arrivals

My organisation is somewhat uniquely placed in comparing the Department’s approach to processing of the claims of asylum seekers arriving by boat informally during say, 2000 and 2001, and then in 2006.

During 2001, for example, we provided independent legal representation to groups of mainly Afghan and Iraqi Protection Visa applicants held in remote detention centres such as Curtin Immigration Reception and Processing Centre (“IRPC”) and Port Hedland IRPC.

The Department named these processing regimes in remote detention “Taskforces”. Taskforces essentially involved very short periods of approximately one to three weeks in which a team of legal advisers advised and prepared full written, individual applications for refugee status for asylum seekers in large groups, which were then lodged and assessed by Departmental officers in client interviews.

As co-ordinator of legal teams which performed some this work, our overwhelming experience was that the Department brought a ‘siege’ mentality to much of the work under this process, in which there were serious deficiencies in procedural fairness. Common features included:

• Significant delays in clients being able access legal assistance. (Some of clients were held in separation or incommunicado detention for many months, and in some cases threatened with removal, before ultimately being allowed to access legal help. Some of these men, from the persecuted Hazara ethnic minority who had fled from Taliban brutality in Afghanistan, later appear to have had favourable refugee assessments reversed by the Department without their knowledge in seriously questionable, if not arguably unlawful, circumstances, and were only able to procure their release from detention with the intervention of the Courts.)
• Confusing, hostile and at times intimidatory treatment from the outset, framed by an institutional suspicion which started with the assumption that these people may not be, or probably were not, refugees, but rather, cynical opportunists looking for a good migration outcome.
• Unrealistic and overly onerous imposition of conditions on the advice and preparation of claims. (Schedules for our work were dictated by the Department, and required, for example, three to four full Protection Visa applications per day to be prepared from scratch by each legal adviser with clients who we had never met or been instructed by before, who were often traumatised, and who could only communicate through an interpreter. In a normal working day, that’s about one and a half to 2 hours per application!)
• Interviewing of clients by Departmental officers who were often poorly prepared or equipped, with insufficient understandings of the clients’ claims and relevant country information, including on issues concerning cultural background. Questioning was regularly irrelevant, disrespectful, and/or aggressive. Clients were routinely ambushed with purportedly adverse information about themselves or the situation in their home country, with an inadequate opportunity to comprehend or meaningfully respond to such concerns. (A graphic example of the lack of understanding and structural denial of the basic requirements of procedural fairness was the rigid rule that breaks provided before conclusion of the interview were called “natural justice breaks” and no matter the nature of the adverse information, or the state or aptitude of the client to understand the matters at stake, such breaks were to be no longer than 10 minutes. In fact, challenges to this approach by advisers were often characterised by Departmental delegates as unfair and obstructionist. We also witnessed Departmental delegates at the commencement of refugee status determination interviews tell unaccompanied minors as young as 14 from Afghanistan that under Australian law, the giving of false or misleading information could result in imprisonment for 10 years.
• The role of the adviser was commonly severely restricted. There was an institutional lack of appreciation of legal adviser’s role, resulting in a general disinterest or lack of engagement in legal submissions made on behalf of clients.
• ? Lack of consistency in approach and decision-making, in which like cases were routinely treated unlike others, to the extent that it was often difficult to discern why some cases being approved while others were rejected.

In the words of Palmer, we witnessed an “entrenched culture fixed on process and apparently oblivious to the outcomes achieved” where “rigid, step-by-step protocols” designed by Senior Immigration officials in Central office were imposed in an inflexible and procedurally unfair processing regime.

Now for a comparison, post-Palmer.

Some five or so years later, in late January 2006, a legal team from my organisation, including myself, went to Christmas Island on another Departmental Taskforce, as independent legal advisers. This time, the task was to provide legal assistance to the 43 West Papuan asylum seekers who had arrived some two weeks earlier.

Our professional experience was somewhat rare and unique. It is clear that the processing of the West Papuan claims was seen as a significant test case of the new, reforming Department. As I remarked publicly shortly after 42 of our clients were granted Protection Visas in late 2006, our clients were grateful that justice had been done; that their treatment and the due legal processes provided by the Australian Government and the Department had been fair, reasonable, just and decent.

What features of the process contributed to this judgment?

• The West Papuan refugees were treated well and with respect and dignity from the time of their arrival. From our observation, they were treated, quite properly, as if they may well be refugees and accordingly, may have certain rights and needs. This is what should happen, rather than the institutional suspicion and unfairness we had routinely experienced in the past.
• They were promptly provided with experienced, competent legal representatives.
• The process provided time for us to both advise and prepare detailed written claims for submission in support of each person’s formal application for a Protection Visa.
• These claims were examined by a Departmental delegate at an interview with the client, legal adviser and qualified interpreter present. Clients were treated with respect and dignity, and given a genuine opportunity to put their case. Legal representatives were also given a reasonable opportunity to make oral submissions on behalf of clients.
• Post-interview, there was reasonable opportunity for lodgment of detailed legal submissions, including expert evidence.
• It was a process in which there was great flexibility and decisions about the functioning of the process - in an environment where everyone was operating under considerable pressures - were made in a general spirit of cooperation and guided by the aim of achieving fair and reasonable results.
• Evidence and submissions lodged by legal representatives in relation to interference by Indonesian authorities in the refugee determination process were generally well-received and sensitively handled by the Department.

Of course, this is not the full picture. There were further twists in the tale. In response to Indonesia’s fury and threats over the grant of Protection Visas to the 42, the Government presented a radical, rearguard retreat from a commitment to such fair and decent treatment, with the introduction of the Migration Amendment (Designated Unauthorised Arrivals) Bill 2006, which sought to preclude any future refugee applications by people arriving by boat being made in Australia at all, let alone treating them fairly. It represented the sudden ushering in a new era of extreme harshness and potential cruelty – a new policy of ‘Radical Rejection’.

Essentially, at the first sign of external political trouble, the Australian Government’s commitment to a fair and decent process for asylum seekers appeared to be surrendered. This revealed the radical contradictions in Government policy and its reform principles, and thus the inherently fragile and tenuous nature of reform in this context. (More on this later.)

But one legacy, at least, of the Papuan processing is a concrete case study of how processing of asylum claims – albeit illogically, irrationally and at exorbitant expense conducted on Christmas Island under Government policy – should and can be done properly. It is an important precedent, indeed.

(b) Case management, including of vulnerable clients and those with ‘exceptional’ circumstances

In the pre-Palmer era, one of the enduring and intractable problems centered on the Department’s treatment of people detained, as well as particularly vulnerable people in the community. Common concerns included:

• A lack of ‘case co-ordination’ – that is, a lack of a holistic understanding of and approach to a client’s often interrelated health, welfare and legal needs.
• The lack of a consistent approach to clients’ cases within the Compliance and Detention areas of the Department.
• No proper systems for risk assessment regarding a client’s needs and rights. Instead, the system was largely assumption based, including on questions such whether to detain, remove, grant or re-new a Bridging Visa. Consequently, the Department was routinely responding in a rigid and myopic way to an individual’s immigration status, rather than having regard to bigger picture which should properly inform the process.
• An institutional reluctance to acknowledge the particular health, welfare and legal needs of individuals, and a tendency to trivialise or ignore the need to facilitate such assistance.
• Structures, processes and conduct which obscured and avoided responsibility for a client’s needs, to the extent that it was often difficult to discern who to whom such concerns should be addressed.

I want to briefly refer to a refugee case which provides a graphic illustration of the terrible problems and consequential damage which can result from such an approach. The case in question involved a stateless asylum seeker from the Middle East, Ibrahim, who had initially arrived in Australia informally. He suffered from a mental impairment which severely diminished his capacity to accurately present his claims for refugee status. Ibrahim applied for protection, the application was refused and he continued to remain in detention for a number years. Ultimately, he was released from detention by way of a habeas corpus order of the Court. Upon his release, for the first time, he underwent a full needs assessment when a non-government agency with expertise in assisting asylum seekers became concerned about signs of potentially serious psychological issues. Expert health assessments revealed that Ibrahim had a serious intellectual disability which directly diminished his memory and capacity to answer questions about his refugee claims accurately, especially when under pressure. Apparently, such disabilities are difficult to detect with a non-expert eye. It became clear to welfare workers that the client had never given an accurate account of his claims, and that it would necessary to contact family overseas to help with reconstructions is his real history. This had not been identified by the Department when he was in detention. Ibrahim was then able to access intensive, expert legal help to re-put his claims. Upon a Departmental reassessment of his claims, he was found to be a refugee under the United Nations Refugees Convention, and was granted a Protection Visa.

Had the Department undertaken a comprehensive, holistic assessment of Ibrahim’s needs, it is likely that they would have detected barriers to him properly presenting his claims and could have explored avenues to rectify this situation. Of course, this may have not only resulted in less damage to the client, but also the timely recognition of refugee status and quicker attention to treatment of the client’s health and welfare needs.

Progress by the Department post the Palmer report is such that there is now a reduced chance that situations such as that just described would happen now. This is largely due to one of the reform flagships, Case Management (and the related Community Care Pilot), which have been developed and commenced implementation. These are specifically aimed at the better treatment of, and provision of targeted, co-ordinated, holistic assistance to the particularly disadvantaged or vulnerable clients,

Although it is too early to fully assess the case management model, some positive and tangible progress has been made. For example, in a number of cases of which we are aware, the Department has quickly ensured a holistic assessment is undertaken of a client’s needs. This has resulted in prompt referral to independent agencies with expertise in legal, health or welfare matters. This has been facilitated by the formalisation and funding of processes which are aimed at a higher and more consistent degree of collaboration and co-ordination amongst key stakeholders. For example, now the Australian Red Cross, International Organisation for Migration, and certain health and welfare services and legal providers with expertise in working with asylum seekers and migrants are working together with the Department to comprehensively deal with complex cases.

We have also witnessed the Department shift from a common approach of apprehension about seeking and acting on expert health and welfare advice, to a trajectory of readiness, if not, at times, enthusiasm, to do so. And one tangible initiative has been the introduction of Departmental Case Managers and Detention Review Managers, tasked with managing not only holistic needs assessment, but also assessment of whether detention is lawful and reasonable.

And at a conference for lawyers, one must not fail to note in passing that institutional apprehension about formally including legal advisers in any case management processes has recently seen some concrete – albeit delayed - progress, with the inclusion of legal advisers and the provision of some free legal advice structured into Case Management and the Community Care Pilot.

Despite some substantial improvements, one of the principal concerns of Case Management remains lack of consistency in implementation and delivery of the services. Some clients have still fallen through the cracks, and have not been properly assessed in relation to health needs and legal rights, resulting in potentially dire consequences. Some ‘tailored’ care has been inappropriate or needlessly delayed. These problems have been particularly, but not exclusively, present for clients in the community. And although the Compliance Section of the Department has vastly improved its practices, with flexible and reasonable treatment of clients, including those who are ‘unlawful’, now becoming the norm, application of Bridging Visa laws still suffers from unevenness on matters such as work rights and duration of visa grant. Such problems are mirrored in numerous other areas under ‘reform’ construction. Given that one of the hallmarks of fairness in public administration is consistency, these are substantial concerns.

And finally, the tension between imperatives of the reform process and other Government policies has also been evident in Case Management and the Community Care Pilot. A lack of clarity, enduring debate and apparent apprehension on the Department’s part around whether ‘special care’ services should continue for a client who seeks judicial review or Ministerial intervention, is one of clearest cases in point. More work remains for the Department to ensure that the potential tension between the imperatives of ‘removal’ and proper treatment of clients is routinely resolved in favour of the client’s rights, needs and dignity – that is, in a way which is ‘fair and reasonable’. And with a recognition that to achieve this aim, removal may, at times, need to be deferred while the client explores options and is cared for.

(c) Processing of offshore applications

I also want to refer briefly to the processing of offshore applications, for while the Palmer report did not specifically deal with this matter, the post Palmer reform process has rightly developed a fresh framework of values, which include being “an open and accountable organisation”, and “having fair and reasonable dealings with clients”. The Secretary has stressed that these values must not be “cosmetic”, but rather, must be applied to the work done. He has also stressed that it is essential that these values be applied not only by the Department in Australia, but equally to work done by the Department offshore.

Regrettably, in my judgment, there is no substantial evidence that the post-Palmer reforms are taking hold in the operations of overseas posts. Much offshore processing is nothing short of eccentric in the context of Western legal systems in this day and age.

A compelling case in point is the current approach to the processing of applications made by clients under the Refugee and Special Humanitarian Program. Post-Palmer report, openness, accountability, fairness and transparency continue to be almost non-existent in the processing of these claims. For decisions which involve matters which could hardly be more grave – that is, protection from persecution and family reunion – written refusals are issued with a pro forma statement which does not disclose any reasons for the failure of the particular application

Legal advisers are left with no idea of the basis of the refusal. So imagine where applicants and their proposers in Australia stand – usually, baffled and distraught.

The absence of transparency is so fundamental that copies of Departmental file records obtained under Freedom of Information provisions rarely give any further hint of the specific reasons for refusal. If they do, it is commonly a comment as oblique and incomprehensible as “claims not current”. I am reliably informed that this phrase is code for - in the context of an Afghan widow from persecuted minority ethnic group and a family with an adverse political profile in Afghanistan, with five young children on her own and illegal in Pakistan, with a young adult son recently recognized as a refugee in Australia - that she no longer has a need for human rights protection and can return to Afghanistan.

My experience is that when advisers seek explanations for such refusals, it can be left to another Departmental official to read between the lines – that is, if there are any lines. In many cases, there are not.

In processing of offshore applications under the general migration program, similar systemic problems persist. They include arbitrary use of documentary or expert evidence, and the application of sweeping, unsupported cultural stereotypes on issues crucial to determination of the visa application, such as age, family relationship and identity.

2. Treatment of stakeholders

I now turn briefly to the second category under which I want to assess post-Palmer progress – namely, treatment of stakeholders.

Why does this issue matter? Principally, because if stakeholders are doing their job properly, they should be well-positioned to comment on the things that matter most to clients in their interactions with the Department. They should also be well-placed to influence and help shape the Department’s approach to clients and their communities. They should be able to enrich the Department’s understanding of the content of its self-proclaimed duty to have “fair and reasonable dealings with clients”.

We acknowledge the Secretary and his Department have prioritised stakeholder engagement, and that stakeholders are to be considered “an asset, rather than a liability or obligation” (even though I can think of occasions when it mustn’t feel like this!)

Back to a darker past for a moment, in which the following features of stakeholder engagement by the Department were common:

• Lack of frequent or genuine dialogue, debate or preparedness to openly discuss operational or client-based issues, including a defensiveness and withholding of information about the bases of decisions made or proposals for change.
• Lack of responsiveness or follow-through on requests for information about systemic or individual client-based issues.
• A ‘fortress’ mentality in some senior ranks, involving a particular lack of accessibility and engagement with stakeholders
• Elitism, in which key stakeholder fora failed to have appropriate representation of those working directly in the fields of relevance.
• Inadequate dissemination of key information to less senior Departmental officials by those in Central Office.
• Reluctance to consult with known critics.
• An institutional misunderstanding and mistrust of legal practitioners and their role in the system.

Post-Palmer, there have been substantial and tangible improvements in this area relating to both attitudinal and practical change.

On the attitudinal front, the Department has displayed a far greater openness and interest in engaging in meaningful and respectful dialogue with stakeholders. This has included an increased willingness at both state and national levels to discuss and debate issues of concern on client-specific, as well as more systemic issues.

In relation to practical measures, there has been a significant increase in the development of fora for dialogue, such as the establishment of Client Reference Group meetings in some States.

An area of particularly important progress has been the inclusion of key stakeholders on national steering/reference or advisory groups to collaborate on the development and implementation of new reform programs, such as the Community Care Pilot. Stakeholders chosen have been from agencies which directly deal with the issues at stake, including legal practitioners.

One tangible development of real significance has been the establishment of the Detention Health Advisory Group, comprising experts from right across the health sector, including some well-known trenchant critics of detention policy and past practices. This group has ensured that health care services are now removed from the detention contracts, and are instead tendered out separately to remove potential conflicts of interest in the operation of the detention regime and provision of health care. This reform was implemented soon after the Palmer report, after having sat gathering dust for four years after its recommendation by the separate Immigration Detention Advisory Group.

Other areas of real progress have involved:

• Increased follow-through, responsiveness and initiation of further dialogue by Departmental officials.
• Implementation of some stakeholder suggestions, clearer explanations of progress, and increased preparedness to disclose reasons for non-implementation of some initiatives.
  
  
• Extensive and energetic efforts by senior officials, to build relationships across a wide range of stakeholder groups.

And yet, there are some distinct problems in this area, which include:

• Inconsistent levels of responsiveness, including a clash of cultures, which has involved a reluctance by some to change and improve engagement.
• Lack of focus, in which there is a scattergun approach to consultation, which is at times confusing and difficult to meaningfully participate in.
• Lack of continuity, due to frequent changes of senior personnel overseeing the reforms in key areas.
• Lack of co-ordination of consultation across different fora.
• Lack of representation of community legal sector at peak fora, such as the Department/IGO-NGO Consultations.

Stakeholder engagement is also vulnerable to the dictates of external Government policy factors. For instance, in early June 2006, the Department held a day-long debriefing session with key agencies and officials involved with the West Papuan Taskforce and settlement of the clients in Melbourne. It was a commendable idea; the purposes of this project were consistent with the reform principles, and it is far from certain that such a forum would have been proposed pre-Palmer. However, this session was held at the very point when the offshore processing Bill had been introduced into Parliament and looked likely to become law. The effect of the proposed laws would have been to eliminate the very possibility of using the proper processing precedent at all, given that they sought to deprive all future boat arrivals of the ability to apply for protection in Australia at all. So, paradoxically, we were debriefing on lessons learnt about something which looked to be non-existent in the near future.

But ultimately, would Mick Palmer still report now on these matters in same way that he did so in 2005 when he stated: “…the Inquiry found considerable evidence of deafness to the concerns voiced repeatedly by a wide range of stakeholders, a firmly held belief in the correctness and the appropriateness of the processes and procedures that exist, and a culture that ignores criticism, is unduly defensive, process motivated and unwilling to question itself.” I am certain he would not.

3. Conclusion

I have mentioned how the shape and trajectory of the reform process is very fragile and tenuous at its core. Why? Because it remains ever-vulnerable to the dictates of the external political environment.

Just as when only 400 or so asylum seekers arriving boat in Australia between 1989 and 1992 triggered the introduction of a mandatory detention system.

Just as, pre-election, 2001, further asylum seeker boat arrivals, relatively miniscule in numbers by international standards, triggered the legislative ‘excision’ of parts of Australian territory.

Just as the Indonesian fury at the grant of protection visas to 42 West Papuans triggered an albeit failed attempt to legislate that all future boat arrivals be denied the right to apply for protection in Australia, and be ‘exiled’ to Nauru instead.

The reality is that the current reform process is constantly subject to being reined in by the fact that the fundamental planks of the Government’s Immigration policy are in many respects at odds with the principles of the Departmental reform process itself. Framed by fair and reasonable treatment of clients, the reforms are potentially limited because, in many areas, we don’t have fair and reasonable Government policies. Adherence to the reform imperatives depends on the external environment remaining substantially unchanged and benign.

The situation of eight Burmese asylum seekers, who we represent, is stark reminder of this tension. Our clients arrived by boat in August last year. The then Immigration Minister, Senator Amanda Vanstone, who had a discretion to allow the men to remain in Australia and apply for protection under Australian law, exercised her discretion against them. No reasons were given. No legal review or other redress was available. They were removed to possible indefinite exile on Nauru. This decision ran radically counter to the reform process in at least two key respects: first, it deprived the Burmese men of access to the due legal processes and other benefits of the reform process itself, which do not extend to the ‘Pacific Solution’; and secondly, they have become subject to a policy and practices which, rather than focusing on holistic care, have been assessed independently on concrete evidence to have resulted in the terrifying human destruction of many. Rather than operating on values of openness and accountability, it is a policy which can be characterised as ‘out of sight, out of mind, out of rights’. And, it would seem, we could add to that – outside the reform process.

Ultimately, the reform process has involved some notable improvements in numerous key areas, while poignant tensions and problem areas remain. The reframed core principles are correct, and much will depend on effective and extensive implementation of these matters, as well as the political environment remaining relatively unchanged and benign.



In a broad sense, much will depend on how focused, disciplined and robust the Department can be in ensuring that the principles and programs of the reform process are implemented without fear and in favour of the Government’s policy to comprehensively accept the recommendations of the Palmer and Comrie reports and to act on them. And to do so with as little interference or intrusion as possible from other key aspects of the Government’s Immigration policy which are at fundamental odds with this agenda.

David Manne

Co-ordinator

Principal Solicitor and Registered Migration Agent No. 0001707

REFUGEE & IMMIGRATION LEGAL CENTRE INC.