Immigration – Leave to remain. The respondent Secretary of State had discharged the burden of proof, under para 322(1A) of the Immigration Rules, that the degree certificate relied on by the claimant in his application for further leave to remain as a Tier 2 Skilled Worker migrant had been a false document. The Court of Appeal, Civil Division, in dismissing the appeal, further held that the Secretary of State's finding of dishonesty had been made out.