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Justice Matrix · Case profile

KM (Nigeria), R (On the Application Of) v Secretary of State for the Home Department (ECAT: where stay necessary)

United KingdomUpper Tribunal (Immigration and Asylum Chamber)2025Europe
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 central issue in this judicial review case is to determine the conditions under which a stay is necessary within the Early Consideration of Asylum Tribunal (ECAT) process, specifically impacting a Nigerian national.

Key holding

What the court decided

The Upper Tribunal held that a confirmed victim of modern slavery's right to a residence permit because their "stay is necessary owing to their personal situation" under Article 14(1)(a) ECAT does not extend to remaining in the UK to defend criminal proceedings arising from forced criminality; that falls outside Chapter III's protective purpose. On Article 14(1)(b), where the Competent Authority has referred a positive conclusive grounds decision to the police and the police confirm the person's presence is not required to investigate or prosecute offences, no further steps are required of the Secretary of State. The SSHD also lawfully assessed mental-health needs against treatment available in Nigeria, and the refusal of modern slavery discretionary leave did not engage Article 8 ECHR. The applicant's challenge accordingly failed.

Issue areas

Categories

asylumrefugee
Source

Authoritative link

Source of record
https://caselaw.nationalarchives.gov.uk/ukut/iac/2025/92
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