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Consultation Responses: Immigration


Immigration Detention September 2018

We maintain that the UK’s immigration detention policy is unjustifiable and highlight concerns about the adequacy of processes relating to identifying vulnerable persons who should not be held at Larne House.

Asylum Support Rates September 2018

The asylum support rates are wholly inadequate at keeping asylum seekers and their children out of poverty.  Significant reform is needed and all asylum seekers should be granted permission to work.

Law Centre (NI) submission to UN Special Rapporteur on contemporary forms of racism, racial discrimination, xenophobia and related intolerance June 2018

We met the Special Rapporteur on Racism during her visit to Belfast in May 2018. In this written submission we outline issues including: access to benefits, asylum and refugee matters, redress for victims of exploitation, immigration detention and matters relating to immigration data and advice.


All Party Parliamentary Group on Modern Slavery & Human Trafficking: Inquiry into the situation of unaccompanied and separated minors in Europe  May 2017

Northern Ireland has the skills and capacity to be involved in the resettlement of child refugees.



Draft Department of Justice Human Trafficking & Modern Slavery Strategy 2016/2017 September 2016

Consultation on Border Force approach to Human Trafficking August 2016

We are pleased that the Independent Chief Inspector is undertaking an inspection on Border Force’s approach to victims of trafficking. We are very concerned that statistics show that Border Force rarely identify victims, which suggests that victims are not promptly being identified. We recommend a number of issues for the Inspector to look at.

Law Centre (NI) response to the Home Office Consulation on Short Term Holding Facility Rules April 2016

While it is good that the Home Office is finally moving to issue Short Term Holding Facility Rules (which will govern detention at Larne House), we think they need to be much more focussed on ensuring that vulnerable categories of people are quickly identified and released from detention. This would include victims of trafficking, victims of torture, pregnant women, etc.  



Law Centre (NI) response to DHSSPS consultation on independent guardianship regulations Nov 2015

We agree with DHSSPS that Independent Guardians should be experts in thier work but believe that the proposed social worker criterion would be too restrictive and may unnecessarilly restrict the pool of  potetially qualified applicants.

Law Centre (NI) response to the Home Office Consultation on reforming support for 'failed' asylum seekers  September 2015

We believe these proposals are retrogressive and will leave those affected in an even more vulnerable situation by exacerbating instances of destitution. Our experience is that the asylum support system is already insufficient to enable recipients to provide for their 'essential living needs.'

These proposals will compound the hardship experienced by asylum seekers including by reducing NASS support rates for single adults and removing additional payments to children.

In evidence to a Parliamentary Inquiry on behalf of a number of Northern Ireland voluntary and community organisations in 2012 we cited numerous examples of asylum seekers struggling to take care of their children's basic needs. We explained that charities’ resources were extremely stretched and were unable to meet all the needs. We do not support the proposals. Instead, we would ask the Home Office to consider the recommendations submitted to the Parliamentary Inquiry in 2012.

DOJ Human Trafficking and Exploitation Strategy August 2015

We suggest a number of amendments / new initiatives for Department of Justice’s Human Trafficking and Exploitation Strategy. We are particularly keen to ensure that all victims of exploitation (whether victims of trafficking or forced labour) have the same entitlement to support and assistance.

GRETA Second Evaluation Round of the United Kingdom  June 2015

The Group of Experts (GRETA) who monitor the implementation of the Council of Europe’s Trafficking Convention are preparing for their second evaluation of the UK. We have asked the Group of Experts to note a number of positive anti-trafficking developments in Northern Ireland but we also highlight issues that need addressing. 

British Irish visa systems  March 2015

We call for the British and Irish governments to recognise each others’ visas so as to allow for smoother travel between jurisdictions. Concerns about current cross border immigration enforcement operations must be addressed.



Parliamentary Inquiry Immigration Detention Oct 2014 

We argue that the UK's immigration detention policy is wholly contrary to UNCHR's guidelines and at odds with detention policy across Europe, which is extraordinary and unjustifiable.  We also outline a number of Northern Ireland specific detention issues.

OFMDFM: Racial Equality Strategy  Oct 2014

We have signed up to the Common Platform paper which has been agreed by organisations working for and with people from BME backgrounds living and working in NI: Sign up to the racial equality common platform

In our short response, we focus our thinking on the immigration chapter and outline some initatives that OFMDFM could include in the Strategy's Action Plan. 

Extending Gaurdianship Separated Children Sept 2014 

NICCY and Law Centre (NI) call for an amendment that will extend Legal Guardianship to all separated children. We argue that a Legal Guardian can help identify victims of trafficking as well as to help protect other vulnerable children from being trafficked.

Home Office National Referral Mechanism Review Sept 2014

We call for significant reform of the National Referral Mechanism, including removing the Competent Authority role from the Home Office; putting the NRM on a statutory footing and introducing a right of appeal for those who get a negative decision.



NIA Justice Committee: Morrow Trafficking Bill  November 2013

In our view the Morrow Trafficking Bill contains a number of innovative features: it has potential to protect victims of forced labour as well as victims of human trafficking; it gives victims a clear legislative entitlement to support and assistance; it provides for a child trafficking guardian and creates a Northern Ireland rapporteur. We believe all these provisions would be extremely valuable.

Home Office: Tackling illegal immigration in privately rented accommodation August 2013 

In this joint response with Housing Rights Service, we strongly object to the proposal to require landlords to conduct immigration checks on potential tenants.



Children's Society: Parliamentary Inquiry into Asylum Support for Children Law Centre (NI) and Others December 2012

We argue that the asylum support system fails to keep children out of poverty and call for urgent and substantial reform. The response draws upon material provided by a range of NGOs working in NI with expertise in this area and is endorsed by Barnardo’s NI, HAPANI and NICRAS.

JCHR: Inquiry into Human Rights of Unaccompanied Migrant Children October 2012 

We give the Westminster Joint Committee on Human Rights an overview of issues faced by separated children in Northern Ireland and we highlight recent developments and examples of good practice.

LPPS: LCNI Response to Public Prosecution Service's Policy for Prosecuting Cases of Human Trafficking September 2012

We are pleased that PPS is developing guidance. We emphasis the complexity of trafficking  cases and highlight the need for PPS to consult with victims more closely. This response is endorsed by Amnesty International.

DOJ and DHSSPS: Guidance on adult victims of trafficking August 2012

DOJ: Consultation on Sexual Offences Act 2003 and Asylum and Immigration (treatment of claimants etc) Act 2004 Part 2 June 2012

In a joint response with Amnesty International, we urge DHSSPS to play a full role as a First Responder in adult trafficking cases.

DOJ: Introduction of scheme on early removal of Foreien National Prisoners June 2012



Tribunal Service Bail Guidance for Immigration Judges December 2011

We propose a number of changes to the Bail Guidance that woudl ensure that the detainee is fully aware of the case against her/him.  We also urge Judges to require that UKBA substantiates any assertion of an 'imminent removal'.


UKBA: Family Migration October 2011


GRETA: Law Centre Submission to the Council of Europe's Group of Experts on Action Against Trafficking in Human Beings October 2011


UKBA: Employment related settlement, Tier 5 & overseas domestic workers September 2011


Introducing fee charges for appeals in the Immigration and Asylum Chambers of the First-Tier Tribunal and the Upper Tribunal January 2011


UKBA: Limits on Non-EU Economic Migration - UKBA September 2011

We object to a cap on migration.  However, if a cap is introduced it must contain suitable treansitional arrangements for 'in-country' migrant workers and should not limit dependents or interfere with family life.



Response to the Migration Advisory Committee consultation on a migration cap  August 2010

We recommend that the Migration Advisory Committee set the migration cap in the most flexible manner possible and that it recommends a Northern Ireland Shortage Occupation List.


Review into ending the detention of children for immigration purposes  July 2010


NICTS consulation: In-Court Interpretation Services May 2010


While we support the proposal to expand the publication of asylum data, we would urge the Home Office to publish full regional statistics on immigration and asylum matters.

The Law Centre is alarmed by UKBA proposals to introduce further cuts to the asylum support system.


We strongly support the joint efforts of the Northern Ireland Human Rights Commission and the Irish Human Rights Commission in pushing for the ratification of the UN Migrant Workers Convention 1990 in both jurisdictions.


UKBA intends to simplify the Immigration Rules. We welcome the proposal to retain discretion that enables UKBA to make positive decisions outside the Immigration Rules in exceptional circumstances. However, we also outline concerns relating to other proposals.



UKBA:  Charging for immigration and visa applications December 2009


We oppose UKBA’s proposal to introduce a points based test for citizenship.


UKBA: Oversight of the Immigration Advice Sector  August 2009



BA CONSULTION: Immigration Appeals: Fair Decisions, Faster Justice October 2008


JCHR Call for Evidence: Draft Immigration & Citizenship Bill  November 2008


NI Prison Service Foreign National Prisoner Strategy  June 2008

We are not in favour of a mandatory Early Removal Scheme.  We highlight th eimportance of specialist legal advice in respect of all deprtation cases.

BIA: Keeping Children Safe from Harm  April 2008


BIA: Visitors Consultation  March 2008


Home Office: Marriage Visas: Pre-Entry English Requirement for Spouses  February 2008



Controlled Access to the UK Labour Market for A2 Workers  September 2007


European Commission: EU Green Paper on the future Common European Asylum System September 2007


BIA:  Simplifying the Immigration System August 2007


BIA Consultation:  Planning Better Outcomes and Support for Unaccompanied Asylum Seeking Children June 2007


Home Office:  The UK Borders Bill May 2007


Establishing a Migration Advisory Committee  January 2007



Home Office Immigration and Nationality Fees (PDF) December 2006


Habitual Residence Test Following the Bhakta Case  September 2006


Asylum and Immigration Tribunal (Procedure) (Amendment) Rules 2006  September 2006


European Union Asylum Qualification Directive  August 2006



Home Affairs Committee in Enquiry into Immigration Control  December 2005


Selected Admission - Making Migration Work for Britain  December 2005


Asylum and Immigration Tribunal Review  December 2005


Legal Aid for Asylum Appeals  May 2005


New Rules for Immigration Tribunal Procedures January 2005



Transfer of Immigration Detainees  March 2004




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