2016] The Protection of Stateless Persons in Australian Law 435 Table 5: Ethnicities and Receiving Countries of Former Habitual Residence Ethnicity ‘Receiving country’ Faili Kurd Iraq and Iran Palestinian ‘West Bank/Gaza’, Israel and ‘Occupied Territories’, ‘Palestine Territories’, Syria, Qatar, Jordan, United Arab Emirates and Lebanon Rohingya Myanmar Bidoon Iraq and Kuwait Hathaway and Foster suggest that: Insofar as a stateless person has more than one country of former habitual residence, it suffices for her to meet the well-founded fear test in relation to one of those states, and to show that she is not able to return to, and receive protection in, any other country of former habitual residence.182 However, in the decisions we examined where the applicant potentially had more than one country of former habitual residence, the decision-maker did not always explore this.183 In one decision, the decision-maker recognised the possibility that a stateless person could have more than one country of former habitual residence, but found that the relevant country was the one with which the applicant’s relationship was ‘more broadly comparable to that between a citizen and his or her country of nationality’.184 182 Hathaway and Foster, above n 7, 75. See also UNHCR, Handbook on Protection of Stateless Persons, above n 20, 11 [18]. 183 1311115 [2013] RRTA 822 (25 November 2013); 1113737 [2012] RRTA 958 (25 October 2012); MZZQN v Minister for Immigration and Border Protection [2014] FCCA 2886 (10 December 2014). 184 1215874 [2013] RRTA 585 (26 August 2013) [104] (Member Fordham).

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