The Internal Flight Alternative in Norway: the law and practice with respect to Afghanfamilies and unaccompanied asylum-seeking childrenA mini-assessment commissioned by UNHCRBy Jessica SchultzChr. Michelsen InstituteContents1.Introduction . 21.1The treaty basis for IFA practice in refugee law . 21.2 The legal criteria for IFA application under the Refugee Convention . 41.2.1 What more? The legal basis for additional criteria for IFA practice . 51.3 The origins and development of IFA practice in Norway . 61.4 The legal parameters for IPA practice in Norway . 71.4.1 The current IFA test: the availability of “effective protection”. 102.Analysis of Norwegian IFA practice vis-à-vis Afghan families and UMs . 132.1 Effective protection in Norwegian law and practice . 172.1.1 Physical security . 182.1.2 Social and economic security . 202.1.3 Other human rights and humanitarian factors . 242.23.Procedural issues . 272.2.1Burden of proof . 272.2.2Notice and right to be heard . 27Conclusions . 301
1. IntroductionThe internal flight alternative (IFA) is a limit on refugee status that potentially applies when aclaimant’s risk of persecution is confined to a specific area of a country. It permits a state torefuse refugee status to a person who faces persecution or similar serious harms in the area ofprevious residence, but can presumably live safely somewhere else in the country. Forexample, a young Afghan who resisted forced recruitment by the Taliban in Kunduz may bereferred to Kabul for protection.Although there is no mention of the IFA in the 1951 Refugee Convention, IFA practice iscommon in many state parties, including Norway. In Norway, the scope for IFA practice hasrecently expanded, following amendments to the Immigration Act which came into force inOctober 2016. This study reviews the law and practice of IFA application in Norway in lightof international legal standards prescribed by the 1951 Convention, relevant UNHCRguidance and international human rights law. It focuses particularly on application of the IFAvis-à-vis two specific groups of refugee claimants with Afghan nationality: families withchildren and unaccompanied and separated minors (UAMs). Individuals from these groupsare regularly denied status because they could presumably find protection somewhere inAfghanistan, for example Kabul, despite the deteriorating security there.The main sources for my analysis include practice notes produced by Directorate ofImmigration (UDI), and the Immigration Appeals Board (UNE), and a small sample of casesprovided for purposes of this research by UDI and UNE. This sample includes 9 first-instancedecisions concerning UAMs and 7 concerning families, as well as 4 second-instance decisionsregarding families and 2 regarding minors (22 cases total).1.1 The treaty basis for IFA practice in refugee lawArticle 1A(2) of the Refugee Convention defines a ‘refugee’ as someone whoowing to a well-founded fear of being persecuted for reasons of race, religion, nationality,membership of a particular social group or political opinion, is outside the country of hisnationality and is unable, or owing to such fear, is unwilling to avail himself of theprotection of that country; or who, not having a nationality and being outside the countryof his former habitual residence is unable or, owing to such fear, is unwilling to return toit. 11Article 1A(2) Refugee Convention. UN General Assembly, Convention Relating to the Status ofRefugees, 28 July 1951, United Nations, Treaty Series, vol 189, 137. The opening phrase of thisdefinition, “(a)s a result of events occurring before 1 January 1951”, was removed in the 1967Protocol. UN General Assembly, Protocol Relating to the Status of Refugees, 31 January 1967, UnitedNations, Treaty Series, vol. 606, 237. Because the vast majority of state parties to the 1951Convention are also party to the Protocol, the “modern” refugee definition, which encompasses futurerefugees from any region of the world, applies in these jurisdictions. As of May 2017, there were 1452
This provision is satisfied when the claimant is 1) outside his or her country of origin; 2) canestablish a legitimate fear of persecution for a Convention ground; and 3) is unable orunwilling, owing to the well-founded fear, to avail him or herself of that country’s protection.For the first three decades of practice under the Refugee Convention, refugees were found tosatisfy these requirements if a well-founded fear of persecution was established anywhere inthe country of origin. There is nothing in the ordinary terms of Article 1A(2) that compel IFApractice. Nonetheless, states in northern Europe (Germany and the Netherlands) beganimplying an IFA limit from the mid-1970s onwards, initially in claims involving minoritygroups from Turkey. 2 In its 1979 Handbook, UNHCR responded to incipient IFA practicewith a clarification that the “fear of being persecuted need not always extend to the wholeterritory of the refugee’s country of nationality” to qualify for refugee status. 3 It further statedthatin ethnic clashes or in cases of grave disturbances involving civil war conditions,persecution of a specific ethnic or national group may occur in only one part of thecountry. In such situations, a person will not be excluded from refugee status merelybecause he could have sought refuge in another part of the same country, if under allcircumstances it would not have been reasonable to expect him to do so. 4Based on this language, some states have concluded that if a person’s risk of persecutioncould be reasonably overcome through the act of relocation, there is no “well-founded” fearin the country of origin. Although Norwegian IFA practice developed from the samerationale, current Norwegian law frames the IFA more generally, as an exception to refugeestatus. 5 Section 28 of the Immigration Act outlines two distinct bases for refugee status. Thefirst, in paragraph 1(a), codifies the traditional definition set out in Article 1A(2) of theRefugee Convention. The second, in paragraph 1(b), provides refugee status to persons whoface a real risk of other serious harms (torture, inhuman or degrading treatment) in the countryof origin. Both grounds for refugee status are subject to the same IFA test. Paragraph 5 of theAct provides, in relevant part, the following:parties to the 1951 Convention and 146 parties to the 1967 Protocol. An updated list of ratifications isavailable at https://treaties.un.org.2See, for example, the District Court of Almelo decision of 11 May 1977, RechtspraachtVreemdelingenrecht (RV) 1977 N 21. Cited in Roel Fernhout, Erkenning en toelating als vluchteling INederland (Kluwer 1990).3UNHCR, Handbook on Procedures and Criteria for Determining Refugee Status (Geneva 1979) para91.4Ibid. Emphasis added.5In the leading textbook on Immigration Law in Norway, the “internal flight alternative” is describedas one of three exceptions to refugee status; the other two are exclusion (under Articles 1D and 1F) andcessation (Article 1C). Øyvind Dybvik Øyen, «Rett til flykningstatus og asyl» in Øyvind Dybvik Øyen(ed), Lærebok i utlendingsrett (Universitetsforlaget 2013).3
The right to be recognized as a refugee under the first paragraph shall not apply if theforeign national may obtain effective protection in other parts of his or her country oforigin than the area from which the applicant has fled. 6Thus, even though the claimant has fulfilled the core criteria (i.e. has a well-founded fear, orfaces a real risk of serious harm), refugee status will not be recognized if a valid IFA exists. Inthe preparatory works to this Act, the Ministry of Labor and Inclusion (responsible forimplementing immigration laws at the time) justified this implied exclusion clause withreference to the subsidiary (or “surrogate”) nature of refugee law. 7 Accordingly, whereprotection is available within the country of origin, “backup” protection by another state is notnormally required.1.2 The legal criteria for IFA application under the Refugee ConventionAs an implied limit on the scope of Convention protection, IFA application is subject tocertain restraints. 8 As a threshhold requirement, the IFA must be safely, legally andpractically accessible. The claimant cannot face dangers en route like “mine fields, factionalfighting, shifting war fronts, banditry or other forms of harassment.” 9 Furthermore, he or shemust have the legal right to travel to the area, to enter and not least to reside there. 10It is also clear that conditions in an IFA cannot give rise to an independent claim for refugeestatus. Thus, the area must be free from an immediate or foreseeable risk of persecution,including risks that may have arisen subsequent to the applicant’s flight. These can include,for example, risks that may attach to one’s status as a “separated woman”, “survivor of sexualviolence” or even an “internally displaced person.” As a “returned asylum seeker”, youngAfghans may be associated with the West, “either ideologically or in terms of wealth.” Theconsequences—extortion, kidnapping, and even torture—may reach the persecutorythreshhold or in other ways render return fundamentally unsafe.Article 33 of the Refugee Convention, which prohibits refoulement “in any way” to a threat tolife or freedom, also prohibits removal where an indirect risk of persecution is present. In thepractice of many European states, including Norway, this safety assessment is focused on thequestion of whether the situation would be so harsh as to constitute “inhuman or degrading6Norwegian Immigration Act (2010) §28(5). Available at tion-act.html?id 585772 (accessed May 18, 2017).7Ot.prp. nr. 75 (2006-2007) para 188.8.131.52On the IFA as an implied limit on the right to refugee status, see Schultz, J and Einarsen, T, ‘TheRight to Refugee Status and the Internal Protection Alternative: What Does the Law Say?’ in BursonB and Cantor DJ (eds), Human Rights and the Refugee Definition: Comparative Legal Practice andTheory (Brill Nijhoff 2016), 288-290.9UN High Commissioner for Refugees (UNHCR), Guidelines on International Protection No. 4:"Internal Flight or Relocation Alternative" Within the Context of Article 1A(2) of the 1951 Conventionand/or 1967 Protocol Relating to the Status of Refugees, 23 July 2003, HCR/GIP/03/04, available at:http://www.refworld.org/docid/3f2791a44.html (accessed 20 May 2017) para 10.10Ibid, para 12.4
treatment” in violation of Article 3 of the European Convention on Human Rights (ECHR)and other instruments. 11As UNHCR and others point out, the baseline IFA analysis requires a more robust assessmentof minimum human rights guarantees. The proposed alternative must provide effective anddurable protection against the risk of persecution established. This requirement is not onlyimplicit in Article 33, but it also aligns with the treaty’s purpose to provide stable protectionagainst a risk of persecution for certain discriminatory reasons. Durable protection is usuallyonly available when the state or state-like authority has secure control over the territory.UNHCR’s newest Guidelines on International Protection, addressing situations of armedconflict and violence (2016), reiterate that “(o)nly when the situation of armed conflict andviolence and its impact is geographically limited and confined to a specific part of the countrywould it be relevant to assess whether an internal flight or relocation alternative exists.”121.2.1 What more? The legal basis for additional criteria for IFA practiceCurrent state practice and UNHCR guidance reflect a broad agreement that the existence of awell-founded fear of persecution in one area triggers a hightened threshhold for removal toanother within the claimant’s country of origin. This is captured, for example, by the“reasonableness” prong of the IFA test advocated by UNHCR and applied in manyjurisdictions. In its 2003 IFA Guidelines, UNHCR suggests framing the question as whether“the claimant, in the context of the country concerned, can lead a relatively normal lifewithout facing undue hardship.” 13 Basic human rights conditions in the proposed area arerelevant, as are individual factors such as(a)ge, sex, health, disability, family situation and relationships, social or othervulnerailities, ethnic, cultural or religious considerations, political and social links andcomptability, language abilities, educational, professional and work background andopportunities, and any past persecution and its psychological effects. 14Given the recent amendments in Norway, it is worth reiterating that a “reasonableness” or“proportionality” assessment is clearly supported by the IFA’s position as an implied limit onthe scope of Convention protection. 15 The basic criteria for refugee status – a well-founded11UN International Covenant on Civil and Political Rights, Article 7; UN Convention Against Torture,Article 3.12UN High Commissioner for Refugees (UNHCR), Guidelines on International Protection No. 12:Claims for refugee status related to situations of armed conflict and violence under Article 1A(2) ofthe 1951 Convention and/or 1967 Protocol relating to the Status of Refugees and the regional refugeedefinitions, 2 December 2016, HCR/GIP/16/12, available at:http://www.refworld.org/docid/583595ff4.html (accessed 20 May 2017) para 41.13UNHCR IFA Guidelines, para 24.14Ibid, para 25.15See Schultz and Einarsen, supra note 8.5
fear of persecution reflecting an absence of home state protection – may be satisfied even ifthat fear is localized in one area of a state’s territory.I have argued elsewhere that the parameters for IFA practice should be explicitly framedwithin the rules of treaty interpretation codified in the Vienna Convention on the Law ofTreaties (VCLT). The “principle of systemic integration” set out in Article 31(1)(c) of theVCLT demands that the Refugee Convention be applied in harmony with other relevantinstruments, particulary when filling interpretive gaps that the text does not clearly resolve. Inline with UNHCR guidance, this compels a displacement-sensitive assessment of thefollowing factors:-Freedom of movementAccess to cultural/religious/economic networksThe general human rights situationSpecial needs (related to age, disability, gender, lack of nationality)Best interests of the childProspects for family lifeExperience of past persecution 16Given the treaty’s object and purpose to provide stable protection against a risk of persecutionsomewhere, the overarching question is whether a secure and dignified life is possible in theproposed IPA.Before analyzing current Norwegian practice against the normative approach outlined above,a review of how this practice has developed may be useful, and explains some of its uniqueaspects.1.3 The origins and development of IFA practice in NorwayIn Norway, the 1951 Convention refugee concept was first codified in §16 of the 1988Immigration Act. 17 UDI staff members from the 1990s confirm that early IFA practice wasexceptional in nature, based on the narrow limit seemingly provided for in paragraph 91 of theUNHCR Handbook. 18 Einarsen refers to two specific groups subject to the IFA analysis in his1997 overview of the legal position of refugees in Norway: Kurdish village guards exposed topersecution in Kurdish areas of Turkey but not elsewhere in the country, and Tamils from SriLanka who could presumably be returned to Colombo. 19The first formal reference to the IFA appears in the Ministry of Justice s Asylum Guidelines(1998), which came out following concerns raised by UNHCR and others regarding Norway slow recognition rates. 20 These Guidelines clarified a range of interpretive issues related to16Ibid., at 297.Prior to 1988, refugees in Norway were generally granted a humanitarian visa rather than legalConvention status.18Interview with Paula Tolonen, former Deputy Director of UDI, October 30, 2014.19Terje Einarsen, Flyktningers rettsstilling i Norge (Fagbokforlaget 1997) 50.20Ministry of Justice, Guidelines for New Asylum Criteria (Retningslinjer for nye asylkriterier),published on January 13, 1998.176
gender, sexual orientation, and not least the burden of proof. The Guidelines also,significantly, addressed persecution by non-state actors and the IFA:In cases where the applicant will be threatened by non-state groups or individuals incertain areas of the home country, protection in Norway (either in the form of asylum or aresidence permit) is normally not given if he or she will be secured protection in other (forexample government-controlled) areas of the home country. 21The Guidelines further state that there may be cases where, after a holistic assessment of allaspects (health issues, impact on children, links to Norway), the claimant should not becompelled to relocate elsewhere in the home country despite the possibility of securingprotection there. UNHCR’s “reasonableness” criteria thus referred back to the specific issuesmentioned by a separate provision of the Immigration Act concerning residence onhumanitarian grounds. 22 This link between the reasonableness criteria and factors shaping theconcept of humanitarian protection in Norwegian law has entrenched not only a narrow“reasonableness” test in law, but also a perception that “reasonableness” is a discretionarycriterion.1.4 The legal parameters for IPA practice in NorwayThe current Immigration Act (2008) codified, for the first time, the IFA limit. Section 28 ofthe Immigration Act provides as follows:A foreign national who is in the realm or at the Norwegian border shall, upon application, berecognized as a refugee if the foreign national(a) has a well-founded fear of being persecuted for reasons of ethnicity, origin, skincolour, religion, nationality, membership of a particular social group or for reasons ofpolitical opinion, and is unable or, owing to such fear, is unwilling to avail himself orherself of the protection of his or her country of origin or(b) without falling within the scope of (a) nevertheless faces a real risk of being subjectedto a death penalty, torture or other inhuman and degrading treatment or punishmentupon return to his or her country of origin.Thus, §28 paragraph 1(a) incorporates the refugee definition from the 1951 Convention asmodified by the 1967 Protocol, while paragraph 1(b) provides that persons who face treatmentcontrary to Article 3 of the European Convention on Human Rights (ECHR) (and Article 7 ofthe International Covenant on Civil and Political Rights, ICCPR) also qualify for refugeestatus. Both may be limited, as mentioned above, if a valid IFA is available.21Ibid, point 2.According to §8(2), “On the grounds of strong humanitarian considerations, or when the foreignnational has a particular connection with Norway, a work or residence permit may be granted even ifthe requirements are not satisfied.” The Immigration Regulations of 1990 further specified that forcases involving minors the child s ties to Norway should be given special weight. See §21b, FOR1990-12-21-1028.227
Until it was amended on October 1, 2016, §28 para 5 framed the IFA exception as follows:The right to be recognized as a refugee under the first paragraph shall not apply if theforeign national may obtain effective protection in other parts of his or her country oforigin than the area from which the applicant has fled, and it is not unreasonable todirect the applicant to seek protection in those parts of his or her country of origin. 23Despite the drafter’s intentions to the contrary, the Immigration Regulations reconfirmed thelink between the concept of “reasonableness” and the factors underpinning discretionary leaveto remain for humanitarian reasons. 24 The now defunct §7-1 of the Immigration Regulations,which provided further parameters for practice, provided that[e]ven if §28 of the Act is applicable when considering returning an applicant to thearea from which he/she has fled, it shall only be deemed to be unreasonable to directthe foreign national to seek protection in safe and accessible parts of his/her country oforigin if the situation upon return will be such that the person concerned meets theconditions for a residence permit under §38 of the Act. In the assessment of whetherthe conditions for a residence permit under §38 of the Act are met, the fact that theforeign national has no connection with a safe and accessible part of his/her country oforigin is not in itself sufficient.Section 38, setting out the criteria for “strong humanitarian considerations” (“sterkemenneskelige hensyn”) specifically mentions compelling health issues, social orhumanitarian circumstances related to the return situation, and the absence of adequate carefor cases involving minors. However, §38 also permits these factors to be balanced againstcertain state interests including the possible consequences for the number of applicationsbased on similar grounds. Although §7-1 is no longer operational, its underlying assumption –that the “reasonableness” criteria are separate from the state’s core treaty obligation – alsoinforms the current IFA test.23Emphasis added.The preparatory works clearly reference UNHCR guidance as the framework for the reasonablenessassessment. Ot.prp.nr.75 (2006-2007) para 184.108.40.206
Box 1. The 2015 Internal Flight judgment of the Norwegian Supreme Court(HR-2015-02524)The linking of reasonableness criteria with discretionary humanitarian factors waschallenged by claimants in the only case before the Norwegian Supreme Court tospecifically address IFA practice. This case involved an Afghan family refused asylum onthe basis of an IFA in Kabul. The parents were originally from Ghazni province, but hadspent many years in Iran where their two daughters were born. The Board of ImmigrationAppeals (UNE) had concluded that their claim for asylum under the Refugee Conventionwas not credible, but that the family was nonetheless protected on grounds of the securitysituation from return to their area of origin (according to §28(b) of the Immigration Act).1The question was then: could the family safely and reasonably relocate to another part ofAfghanistan?The claimants representatives argued that the IFA test should be interpreted in line withUNCHR s guidance, in accordance with the intention of lawmakers. By linking thereasonableness criteria with discretionary factors instead, they argued that the ImmigrationRegulations overstep their statutory basis in §28(8).1 The Court, however, declined to ruledirectly on this issue. Instead, it simply confirmed that the Immigration Regulations, and thespecific interpretation they codify, have a legal basis in the Immigration Act.1 Even thoughthis case did not address interpretation of the Refugee Convention itself (because the claimwas based on §28(1)(b), not §28(1)(a) of the Act), the Court’s conclusion, or absence of one,was later leveraged by the Ministry of Justice as evidence that the “reasonableness” criterionis not required under refugee law.In addition to the specific language of §28 para 5, other parts of the Immigration Act informthe parameters for IFA practice. In §28 para 3, the Act refers to obligations under theConvention on the Rights of the Child (CRC):[I]n cases concerning children, the best interests of the child shall be a fundamentalconsideration. Children may be granted a residence permit pursuant to the first paragrapheven if the situation is not so serious that a residence permit would have been granted to anadult.This, logically, applies to the asylum determination as a whole, and not only whether a “wellfounded fear of persecution” or real risk of ill-treatment exists in the country of origin. Moregenerally, human rights obligations are implicitly included through §3 of the Immigration Act,which reinforces the primacy of human rights law: “The Act shall be applied in accordance9
with international provisions by which Norway is bound when these are intended to strengthenthe position of the individual.” 251.4.1 The current IFA test: the availability of “effective protection”Following a record high number of asylum claimants during the last half of 2015, theNorwegian government, like others in Europe, introduced a variety of measures to reduce anddivert refugee flows. 26 On December 29, 2015, the Ministry of Justice and Security publisheda Hearing Note on potential amendments to both the Immigration Act and the ImmigrationRegulations. 27 This 150-page document included a wide range of proposals to make Norwayless attractive as a destination for refugee claimants. Among those related to the legal criteriafor protection were proposals to increase the standard and burden of proof, to reintroduce theformer distinction between refugee status and complementary protection, and to remove the“reasonableness” requirement from the IPA test. With respect to this latter suggestion, theMinistry listed all the problems with existing practice: the term “reasonableness” has unclearscope and content; it opens for discretionary assessments that are difficult to structure; it leadsto unequal treatment of similar cases, and results in the grant of refugee status to those withno claim under international law. With respect to the last point, the Ministry claimed that “it isundisputed that international law does not require states to operate with the reasonablenesscriteria.” 28 Despite significant critique from stakeholders in response to this Hearing Note, theMinistry of Justice repeated its position in the final proposal presented to the Parliament inApril 2016. 29 On June 10, 2016 Parliament approved some of the proposed amendments tothe Act, including changes to the IFA provision in §28 para 5. 30 These came into effect onOctober 1, 2016.The current amended paragraph states:25In addition, the Human Rights Act of 1999 ( Menneskerettsloven’ of May 21, 1999 No. 30)provides that the European Convention on Human Rights, the International Covenant on Political andCivil Rights and the International Covenant on Economic, Social and Cultural rights, the Conventionon the Rights of the Child, and the Convention on the Elimination of All Forms of Discriminationagainst Women are fully incorporated in Norwegian law and take precedence over any conflictingdomestic legislation. The legal interpretation of a provision given by a human rights treaty s oversightbody should be given weight, provided that the interpretation is formulated as an authoritative readingand not merely a suggestion regarding optimal practice. See Norwegian Supreme Court, Rt 2009 s.1261.26In 2015, over 30,000 persons submitted a refugee claim in Norway, compared to just under 11,480in 2014. Justis-og Beredskapsdepartementet, Høringsnotat – Endringer I Utlendingslovgivningen(Instramninger II). Available at i/id2469054.27Ministry of Justice and Security, Prop. 16L (2015-2016), Endringer I Utlendingsloven(Innstramninger).28Instramniner II para 220.127.116.11Ministry of Justice and Security, Prop. 90 1 (2015-2016), Endringer I Utlendingsloven mn.(Innstramninger II) para 18.104.22.168Stortinget, Lovvedtak 102 (2015-2016), 10 June 2016.10
The right to be recognized as a refugee according to paragraph 1 does not pertain if theforeigner can receive effective protection in other parts of the country of origin thanthe area from which the claimant has fled.Effective protection implies, as discussed below, that the claimant would not have a wellfounded fear of persecution or face a real risk of torture, inhuman or degrading treatment inthe identified area. In addition, he or she must be able to safely and legally travel there.If a decision-maker concludes that “effective protection” is available within the claimant’scountry of origin, he or she will then assess the humanitarian situation and any specialconnections to Norway in accordance with §38 of the Immigration Act. If “stronghumanitarian considerations” exist, the claimant may receive a residence permit onhumanitarian grounds. As noted earlier, immigration control interests potentially play asignificant role in the overall assessment of whether a residence permit is justified. Thisbalancing is formalized in a specific practice for older UAMs, to discourage future flows.Although UAMs with no (male) caregiver in a proposed IFA will normally fall under theremit of §38, their residence permit may expire at the age of majority (see Section 22.214.171.124,below).126.96.36.199 Consequences and critique of the current parameters for IFA practice in NorwayToday, then, someone with a well-founded fear of persecution for whom “return”
1.2 The legal criteria for IFA application under the Refugee Convention . As an implied limit on the scope of Convention protection, IFA application is subject to certain restraints. 8. As a threshhold requirement, the IFA must be safely, legally and practically accessible. The claimant cannot face dangers . en route. like “mine fields, factional
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