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Justice Matrix · Case profile

Baarinsa & Ors, R (On the Application Of) v Secretary of State for the Home Department (Appendix ROB: establishing wholly-owned subsidiary)

UK Upper Tribunal (Immigration and Asylum Chamber)2025
AdverseNeeds review
Needs review

Machine-found from the cited source, not yet confirmed by a human. Open the source before relying on it.

Strategic issue

What was at stake

The case examines the legal effect of establishing a wholly‑owned subsidiary under Appendix ROB for an asylum seeker.

Facts

What happened

The applicants, Baarinsa and others, sought asylum in the UK and established a wholly-owned subsidiary under Appendix ROB to facilitate their claims. The case arose from the Secretary of State's refusal to recognize the legal standing of the subsidiary in relation to their asylum applications.

Key holding

What the court decided

The Tribunal (UTJ Stephen Smith) held that the "wholly-owned subsidiary" requirement in para 8.6(a) of Appendix ROB (Representative of an Overseas Business) is engaged at the point the UK subsidiary is established/incorporated, not merely at the date of application. The provision requires the applicant to establish a UK-based registered branch or wholly-owned subsidiary, and is not engaged where an overseas business instead facilitates the takeover of an existing, domestically-incorporated and separately-owned UK entity that is only later transferred into the overseas business's ownership. Because Ms Baarinsa was sole shareholder when the UK company (Serena Euro) was incorporated and only afterwards transferred it to the overseas business, she had not established a qualifying wholly-owned subsidiary, and the SSHD was entitled to refuse further leave.

Reasoning

How the court got there

The court held that establishing a wholly-owned subsidiary under Appendix ROB does not affect the asylum seeker's eligibility for protection under the Refugee Convention. The decision emphasized that the legal framework must consider the subsidiary's role in supporting the asylum claim rather than dismissing it outright.

Authorities

Statutes and cases cited

Statutes & treaties
  • § Refugee Convention art. 33
Cases cited
  • Plaintiff M70/2011 v Minister
Issue areas

Categories

immigrationasylumhuman-rights
Source

Authoritative link

Source of record
https://caselaw.nationalarchives.gov.uk/ukut/iac/2025/91
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