DM (Zimbabwe) v Secretary of State for the Home Department

Immigration – Deportation. The Court of Appeal, Civil Division, in dismissing an appeal against a deportation decision, held that First-tier Tribunal (Immigration and Asylum Chamber) (the FTT) had taken into account all the relevant considerations under art 8 of the European Convention on Human Rights. The FTT had not made any express reference to Üner v The Netherlands ([2006] 3 FCR 340) or Maslov v Austria ([2008] ECHR 1638/03), but it had not needed to since: (i) it had had regard to all the relevant considerations; and (ii) the appellant had not been lawfully present in the United Kingdom.

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