IN THE ADMINISTRATIVE COURT CO/798/2020 B E T W E E N: THE QUEEN (on the application of SHAMIMA BEGUM) Claimant - and SPECIAL IMMIGRATION APPEALS COMMISSION Respondent - and SECRETARY OF STATE FOR THE HOME DEPARTMENT Interested Party - and (1) UN SPECIAL RAPPORTEUR ON THE PROMOTION AND PROTECTION OF HUMAN RIGHTS AND FUNDAMENTAL FREEDOMS WHILE COMBATTING TERRORISM; (2) LIBERTY Interveners SKELETON ARGUMENT OF THE UN SPECIAL RAPPORTEUR ON THE PROMOTION AND PROTECTION OF HUMAN RIGHTS AND FUNDAMENTAL FREEDOMS WHILE COMBATTING TERRORISM A. Summary 1. These are the written submissions of the Intervener, the UN Special Rapporteur on the Promotion and Protection of Human Rights and Fundamental Freedoms while Combatting Terrorism (“the UN Special Rapporteur”). The UN Special Rapporteur is grateful to the Court for the opportunity to make these written submissions.1 2. The UN Special Rapporteur’s intervention focuses on a discrete issue of law raised by the Claimant in these proceedings. The Claimant challenges the Special Immigration Appeals Commission’s (“SIAC’s”) determination regarding the Claimant’s right to a fair and effective appeal. It is submitted that SIAC erred in its approach to statutory interpretation in several respects, including by reason of its failure to have due regard to applicable principles of This submission does not constitute a waiver, express or implied, of any privileges or immunities which the United Nations, the Office of the High Commissioner for Human Rights, or the Special Rapporteur enjoy under applicable international instruments, including the 1946 Convention on the Privileges and Immunities of the United Nations and recognised principles of international law. 1 1