“Paragraph 398 of the Immigration Rules sets out the criminality thresholds. An Article 8 claim from a foreign criminal who has not been sentenced to at least four years’ imprisonment will succeed if the requirements of an exception to deportation are met. The exceptions to deportation on the basis of family life are set out in paragraph 399 of the Immigration Rules, and the exception on the basis of private life is at paragraph 399A.” (our emphasis). 4. ‘Unduly Harsh’ 50. We now turn to consider the specific issue of the proper meaning of “unduly harsh” in para 399(a). Those words are, as we have already noted, also found in s.117C(5) setting out ‘Exception 2’ where the proposed deportee has a genuine and subsisting parental relationship with a qualifying child and the effect of his deportation on the child would be “unduly harsh”
“2.5.2 When considering the public interest statements, words must be given their ordinary meanings. The Oxford English dictionary defines “unduly” as “excessively” and “harsh” as “severe, cruel”.” 53. Then at paras 2.5.3 and 2.5.4, the Secretary of State sets out her position, essentially consistent with the submission made by Mr Richard, that the public interest must be factored into an assessment of whether the impact on a child (or partner) is “unduly harsh”: “2.5.3 The effect of deportation on a qualifying partner or a qualifying child must be considered in the context of the foreign criminal’s immigration and criminal history. The greater the public interest in deportation, the stronger the countervailing factors need to be to succeed. The impact of deportation on a partner or child can be harsh, even very harsh, without being unduly harsh, depending on the extent of the public interest in deportation and of the family life affected. 2.5.4 For example, it will usually be more difficult for a foreign criminal who has been sentenced more than once to a period of imprisonment of at least 12 months but less than four years to demonstrate that the effect of deportation would be unduly harsh than for a foreign criminal who has been convicted of a single offence, because repeat offending increases the public interest in deportation and so requires a stronger claim to respect for family life in order to outweigh it.” 54. The same point is made at 3.5.2 where it is stated: “3.5.2 When considering whether the effect on a child of deporting a foreign criminal is unduly harsh, the strength of the family life claim, including the best interests of the child, must be balanced against the public interest in deportation. As a general principle, the greater the public interest in deportation the foreign criminal, the more harsh the effect of deportation must be on the child before it is considered unduly harsh.” 55. In his skeleton argument, Mr Davies relied upon two passages in determinations of the Upper Tribunal in MK (Section 55 – Tribunal options) Sierra Leone[2015] UKUT 223 (IAC) at [46] and BM and Other s (returnees – criminal and non-criminal) DRC CG[2015] UKUT 293 (IAC) at [109] to counter the Secretary of State’s position. 56. In MK , the UT was considering the two questions in para 399(a), namely whether it would be “unduly harsh” for the appellant’s children to live in the country to which he was to be deported and, secondly whether it would be unduly harsh for the children to remain in the UK without the appellant. 57. At [46], the Chamber President (McCloskey J) said this about the “unduly harsh” test: “The determination of the two questions which we have posed in [44](d) above requires an evaluative assessment on the part of the Tribunal. This is to be contrasted with a fact finding exercise. By way of self-direction, we are mindful that “unduly harsh” does not equate with uncomfortable, inconvenient, undesirable or merely difficult. Rather, it poses a considerably more elevated threshold. “Harsh” in this context, denotes something severe, or bleak. It is the antitheses of pleasant or comfortable. Furthermore, the addition of the adverb “unduly” raises an already elevated standard still higher.” 58. Having done so, the UT determined that it would be “unduly harsh” in the following terms: “Approached in this way, we have no hesitation in concluding that it would be unduly harsh for either of the two seven year old British citizen children concerned to be abruptly uprooted from their United Kingdom life setting and lifestyle and exiled to this struggling, impoverished and plague stricken west African state. No reasons or right thinking person would consider this anything less that cruel.” 59. In that passage, the President made no reference to the public interest and was clearly not engaged in a balancing exercise weighing the public interest against the consequences to the children of living in the appellant’s own country but rather was simply focusing on the interests of the children. 60. At [47] McCloskey J turned to consider whether it would be unduly harsh for the children to remain in the UK without the appellant – the issue raised in this appeal. He said this: “The final question is whether it would be unduly harsh for either child to remain in the United Kingdom without the Appellant. This is a different question from that considered in [46] above. We have identified a range of facts and considerations bearing on this issue. Once again, an evaluative judgment on the part of the Tribunal is required. In performing this exercise we view everything in the round. The appellant plays an important role in the lives of both children concerned particularly that of his step son. He is the provider of stability, security, emotional support and financial support to both children. We have rehearsed above the various benefits and advantages which he brings to the lives of both children, coupled with his personal attributer and merits. We remind ourselves of section 55 of the 2009 Act. We acknowledge the distinction between harsh and unduly harsh. We remind ourselves again of the potency of the main public interest in play, emphasised most recently by the Court of Appeal in SSHD v MA (Somalia)[2015] EWCA Civ 1192 . The outcome of our careful reflections in this difficult and borderline case and in an exercise bereft of bright luminous lines is as follows. Balancing all of the facts and factors, our conclusion is that the severity of the impact on the children’s lives of the Appellant’s abrupt exit with all that would flow therefrom would be of such proportions as to be unduly harsh.” 61. Whilst McCloskey J did refer to “public interest in play”, the focus of his reasoning is, again, firmly upon the effects upon the children of remaining in the UK without the appellant. We do not understand McCloskey J to have reached his conclusion that that would be “unduly harsh” based upon the balancing exercise which Mr Richards invites us to adopt. Rather, the focus was upon the “severity of the impact” on the children such that it was “unduly harsh” applying the “elevated” or “heightened” standard which McCloskey J recognised and applied in [46] of the determination. In neither paragraph, in particular in para 46 where the adverb “unduly” is defined, does McCloskey J adopt the approach urged upon us by Mr Richards. 62. In BM and Others the Upper Tribunal was considering ‘Exception 2’ ins.117C(5) of the NIA Act 2002 . At [109], reflecting what was said in [46] in MK , McCloskey J said this: “Given the invocation of “Exception 2” , we must assess the likely impact of the Appellant’s deportation on his spouse. In order for the exception to apply, the impact must qualify as “unduly harsh”
“We accept that life will be very difficult for a young, single mother who will have the additional burden of grieving her husband’s departure abroad in circumstances where the prospects of future reunification are unfavourable. However, these we consider to be typical effects of a husband’s deportation and Parliament has decreed that cases of this kind are insufficient to outweigh the public interest. Furthermore, we take into account the availability of strong family support to the Appellant’s spouse, as we have found above. To this we add that she is a graduate who has evidently been in regular employment and it is, therefore, predictable that she will be able to support herself and her child. We do not overlook the duration of this relationship or its various qualities, all of which we have acknowledged above. However, our conclusion is, balancing all of the relevant facts and factors, that the statutory public interest must prevail by some measure. Accordingly, this Appellant’s appeal underArticle 8 ECHR fails.” 65. We acknowledge that here McCloskey J referred to “balancing of all the relevant facts and factors” and stated that the “statutory public interest” must prevail by some measure. Here, of course, McCloskey J was considering that appellant’s claim under Art 8 at the second stage in MF (Nigeria) . He was not considering the application of para 399. At that second stage, it is inherent in the assessment of proportionality that the public interest must be taken into account in assessing whether there are “very compelling circumstances” (in deportation cases) or “exceptional circumstances” (in other cases) to outweigh that public interest. In our judgment, nothing in [110] detracts from the approach set out in [109] to the phrase “unduly harsh” which was also applied in MK . What is said in [110] related, in our view, to an assessment at Stage 2 and, it is noticeable, that the Upper Tribunal made no specific finding on whether Exception 2 applies. 66. In short, therefore, nothing in MK or BM and Others supports, in our judgment, Mr Richards’ submission that inherent in the adverb “unduly” is a consideration not only of the impact upon the child (or partner) but also the public interest reflected in the individual’s offending. In our judgment, the approach set out in [46] of MK and [109] of BM and Others reflects the correct approach to the phrase “unduly harsh” in para 399(a). 67. Whilst we have considered the Secretary of State’s own view in her own IDI of the phrase’s meaning, it is obvious that that view cannot assist to interpret the phrase “unduly harsh” ins.117C(5) of the NIA Act 2002 . Parliament’s intention must be discerned from the wording of the statute together with any admissible interpretive material which does not, in our judgment, include the Secretary of State’s IDI. Further, we have not found the IDI relevant in interpreting the phrase in para 399 of the Rules. It is established law that an IDI or statement by the Secretary of State cannot affect the plain and ordinary meaning of the words in the Immigration Rules (see Mahad v Entry Clearance Officer[2009] UKSC 16 ). In our judgment, the plain meaning of the word is, as the Upper Tribunal stated in MK and BM and Others . 68. In any event, even if there was an ambiguity in the meaning of the words, the Secretary of State’s guidance cannot be used as an interpretive tool so as to resolve an ambiguity against an individual. In Pokhriyal v SSHD[2013] EWCA Civ 1568 the Court of Appeal recognised that there was a qualification to the approach in Mahad [42} that: “if there is ambiguity in Immigration Rules and the Secretary of State publicly declares that he/she will adopt the more lenient interpretation then the Tribunals and courts may hold the Secretary of State to that assurance.” 69. Here, of course, the Secretary of State’s interpretation is not “more lenient” but is properly viewed as being more stringent. The Court of Appeal accepted that an IDI could not be used to reach an interpretation was more stringent. At [43], Jackson LJ (with whom Longmore and Voss LJJ agreed) said: “I do not think it is possible for the Secretary of State to rely upon extraneous material in order to persuade a court or Tribunal to construe the Rules more harshly or to resolve an ambiguity in the government’s favour. The Secretary of State holds all the cards. The Secretary of State drafts the Immigration Rules; the Secretary of State issues IDIs and guidance statements; the Secretary of State authorises the public statements made by his/her officials. The Secretary of State cannot toughen up the Rules otherwise than by making formal amendments and laying them before parliament. That follows from the Supreme Court’s reasoning in R (Alvi) v Secretary of State for the Home Department[2012] UKSC 33 ;[2012] 1 WLR 2208 .” 70. In our judgment, Mr Richard’s submissions, if correct, would result in any ambiguity in the meaning of the phrase “unduly harsh” being resolved “more harshly” in the “government’s favour” which is precisely what the Court of Appeal said was impermissible. 71. Further, in our view, it is not necessary to interpret the word “unduly” so as to necessarily implant a balancing exercise as put forward by Mr Richards in his submissions and the IDI. It is clear to us that the Secretary of State has, in paras 399 and 399A, set out in detail the number of circumstances where the particular factual matrix has led the Secretary of State to conclude that the public interest in deportation (providing the individual has not been sentenced to at least four years’ imprisonment) is outweighed by those circumstances. The policy in para 399 focuses upon the effect upon children (para 339(a)) or a partner (para 399(b)). The wording of the provision, in itself, reflects that focus: “unduly harsh for the child ”
“I find that it would be unduly harsh for them to remain in the United Kingdom should the Appellant be deported to the United States given that the overwhelming evidence is that being separated from him in that way would, in effect, have a significant an detrimental effect on them and would not be in their best interests. It is not only their evidence but also the evidence of their mother (who, perhaps, has every reason not to favour the Appellant) and their grandmother. Whilst [the appellant’s wife] is able and willing to care for her children in the United Kingdom, it appears to be a fact of life that she struggles financially in the process. The Appellant is able and willing to financially support his family. It is likely that he has a job to go to in the United Kingdom. It is less likely in the short term that he will be able to offer financial assistance to them from the United States as he would have to rebuild a life from scratch. These are children that need to have the opportunity to rebuild their relationship with their father. I find, that this cannot be satisfactorily achieved if the Appellant is living in the United States; ...” 76. In our judgment, for the reasons we have given above, Judge Holder did not fall into error by failing to consider the public interest in reaching his finding that it would be “unduly harsh” for the appellant’s children to remain in the UK whilst he was deported to the USA. (Strictly the eldest child is not under 18 years old and so para 399(a) (and s.117C(5)) does not apply to her. But for these purposes we are content, and nothing to the contrary was suggested to us, to treat the 3 children in the same way.) For those reasons, we reject Mr Richards’ first submission challenging the judge’s decision. 77. Mr Richards’ second submission was that the judge had given inadequate reasons for his finding that it would be “unduly harsh” for the children to remain here without the appellant and that finding was irrational. In particular, the Judge did not set out the “overwhelming evidence” which showed that there was a “significant and detrimental effect” on the appellant’s children so that it was not in their best interests if the appellant were deported to the USA. 78. In our judgment, this submission is well-founded. Whilst we accept that it may well not have been in the children’s “best interests” to be separated from the appellant if he were deported to the USA, we are simply unable to discern what the “overwhelming evidence” was that his deportation would have a “significant and detrimental affect” upon them. One of the appellant’s children is a young adult, aged 19 at the date of the hearing. Another child was aged 17. The third child is somewhat younger, being 13 years old. However, the only basis upon which the judge considered that it would be “unduly harsh” for them to remain in the UK is that their mother, with whom they live, but from whom the appellant is now estranged, “struggles financially”
“The requirement of assessment through the lens of the new Rules also seeks to ensure the decisions are made in a way that is properly informed by the considerable weight to be given to the public interest in deportation of foreign criminals, as declared by parliament in the 2007 Act and reinforced by the Secretary of State (as the relevant Minister with responsibility for operation of the immigration system), so as to promote public confidence in that system in this sensitive area.” 95. Considering whether there are “very compelling circumstances”, we must consider the best interests of the appellant’s two minor children as a “primary” consideration but those best interests may be outweighed by sufficiently weighty matters of the public interest (see ZH (Tanzania) v SSHD[2011] UKSC 4 ). At [26] Lady Hale JSC said: “This does not mean (as it would do in other context) that identifying their best interests would lead inextricably to a decision in conformity with those interests. Provided that the Tribunal did not treat any other considerations as inherently more significant than the best interests of the children, it could conclude that the strength of the other considerations outweighed them.” 96. The public interest reflected in an appellant’s offending may be a sufficiently weighty “other consideration” to outweigh the children’s best interests. 97. Although we do not agree with the judge that there is “overwhelming evidence” of a “significant and detrimental effect” upon the appellant’s children if the appellant were deported, we see no reason to depart from his finding that the appellant’s deportation would not be in the children’s “best interests”