Submission by the United Nations High Commissioner for Refugees in the case AS (Afghanistan) v. Secretary of State for the Home Department

UNHCR’s core submission is as follows. The correct approach when assessing the reasonableness of a proposed internal relocation, flight or protection alternative (“IFA”) is to carry out a single, holistic assessment which focuses upon the circumstances of the individual. That assessment: 2.1 may, as one factor, consider what is ‘a relatively normal life’ in the context of the country concerned; but 2.2 must consider the conditions in the place of relocation against certain objective ‘baseline standards’; and 2.3 must consider the impact of the proposed relocation on the particular individual, having regard to that individual’s characteristics, personal circumstances and past experiences.