444 Melbourne University Law Review [Vol 40:401 While it is not possible to identify length of detention based on nationality in recent statistics, it is clear that without a dedicated visa pathway, stateless persons in Australia are at risk of very prolonged detention, as recognised by a 2012 Australian Human Rights Commission report.228 It reported that ‘[a]s at 15 May 2012, there were 555 people in closed [immigration] detention in Australia who identified as being stateless, 114 of whom had been detained for over 540 days.’229 A perusal of the Commonwealth and Immigration Ombudsman individual reports to Parliament in relation to non-citizens who have been in immigration detention for more than two years reveals many stateless persons being detained for prolonged periods, some for more than three years.230 This is exemplified by the recent case of SZUNZ v Minister for Immigration and Border Protection,231 in which a stateless applicant had been in detention for over five years. The Removal Pending Bridging Visa (‘RPBV’) (Bridging R, Class WR) was introduced following the High Court’s decision in Al-Kateb v Godwin232 in November 2002) (‘C v Australia’); Human Rights Committee, Views: Communication No 560/1993, 59th sess, UN Doc CCPR/C/59/D/560/1993 (30 April 1997) (‘A v Australia’). See also UN Commission on Human Rights, Civil and Political Rights, Including the Question of Tortrure and Detention: Report of the Working Group on Arbitrary Detention, 59th sess, UN Doc E/CN.4/2003/8/Add.2 (24 October 2002) annex (‘Report of the Working Group on Arbitrary Detention on Its Visit to Australia (24 May–6 June 2002)’). There are ample alternatives to detention: see Alice Edwards, Back to Basics: The Right to Liberty and Security of Person and ‘Alternatives to Detention’ of Refugees, Asylum-Seekers, Stateless Persons and Other Migrants, UN Doc PPLA/2011/01.Rev.1 (April 2011); Cathryn Costello and Esra Kaytaz, Building Empirical Research into Alternatives to Detention: Perceptions of Asylum-Seekers and Refugees in Toronto and Geneva, UN Doc PPLA/2013/02.Rev.1 (June 2013); International Detention Coalition, There Are Alternatives: A Handbook for Preventing Unnecessary Immigration Detention) (International Detention Coalition, revised ed, 2015) <http://idcoalition.org/publication/view/there-are-alternatives-revised-edition/>. 228 Australian Human Rights Commission, Community Arrangements for Asylum Seekers, Refugees and Stateless Persons: Observations from Visits Conducted by the Australian Human Rights Commission from December 2011 to May 2012 (2012) 22. 229 Ibid 32, citing Evidence to Senate Legal and Constitutional Affairs Legislation Committee, Parliament of Australia, Canberra, 21 May 2012, 97–8 (John Moorhouse, Deputy Secretary, Department of Immigration and Citizenship). 230 See, eg, Commonwealth and Immigration Ombudsman, Report for Tabling in Parliament by the Commonwealth and Immigration Ombudsman under S 486O of the Migration Act 1958 (Second Report, following Report No 1377/13) <http://www.ombudsman.gov.au/__data/assets/pdf_file/0033/28698/1001208_report_to_par liament.pdf>. Mr X is awaiting the reassessment of his protection claims following the outcome of the judicial review of his independent merits review decision. Since the Ombudsman’s previous report (1377/13), Mr X has remained in community detention. 231 (2015) 230 FCR 272. 232 (2004) 219 CLR 562.