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Home ›AS (Afghanistan) v Secretary of State for the Home Department, 2019


The Court of Appeal set aside the Upper Tribunal’s Country Guidance on internal relocation to Kabul, on the basis that it had made a factual error, wrongly stating that civilian causalities amounted to less than 0.001 per cent, rather than less than 0.1 per cent, of the population of Kabul. However, it did dismiss AS’s ground of appeal, which concerned whether internal relocation would be unreasonable.
Case remitted on limited basis
It would be unreasonable to expect a person to relocate to face economic destitution or existence below at least an adequate level of subsistence. However, it is important to point out that a simple lowering of livings standards or worsening of economic status would not be unreasonable.
UK - AA (Uganda) v SSHD [2008] EWCA Civ 579
UK - AH (Sudan) v Secretary of State for the Home Department [2007] UKHL 49, [2008] 4 All ER 190, [2008] 1 AC 678, [2007] 3 WLR 832
E v Secretary of State for the Home Department [2003] EWCA Civ 1032, [2004] QB 531
EB (Lone Women - PSG - internal relocation – AA (Uganda) considered) Sierra Leone [2008] UKAIT 00090
AAH (Iraqi Kurds – internal relocation) Iraq CG UKUT 00212 (IAC)
Thirunavukkarasu v Canada (Minister of Employment and Immigration) (1993) 109 DLR (4th) 682
Ranganathan v Canada (Minister of Citizenship and Immigration) [2001] 2 FC 164
UNHCR Guidelines on International Protection 2003, Storey [The Internal Flight Alternative Test: The Jurisprudence Re-examined (1998) 10 International Journal of Refugee Law, 499]