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New critique of Home Office country information on Albanian blood feuds


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The Home Office recently withdrew all of its Country Policy and Information Notes (CPINs) on Albania for review. On 20 September 2022 the CPINs reappeared on the Home Office website, with two CPINs – on blood feuds and trafficking – having been updated.

Having previously reviewed and critiqued the October 2018 and February 2020 versions of the blood feuds CPIN, I was unsurprised to see that the new September 2022 version suffers from many of the same flaws. Unlike its predecessors, the September 2022 version argues explicitly that there are “very strong grounds supported by cogent evidence” to justify departing from the Country Guidance case of EH (blood feuds) Albania CG [2012] UKUT 348 (IAC), and that there is now a general sufficiency of protection against blood feuds in Albania. Concerningly, it argues on this basis that asylum claims based on blood feuds can properly be certified as “clearly unfounded” under section 94 of the Nationality, Immigration and Asylum Act 2002.

In my new paper published this week (also available as a downloadable PDF here) I review the new CPIN in detail. I argue that it fails to provide a sufficient basis for departing from EH. Even if the Home Office thinks departure from EH is merited, it cannot properly certify these claims as “clearly unfounded”. I also review the issue of internal relocation, in which the CPIN’s policy summary fails properly to reflect the sources cited in the CPIN itself. In my view, asylum claims based on blood feuds continue to have merit, and it is likely that there will continue to be many grants of asylum in such cases.

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David Neale

David Neale is a legal researcher at Garden Court Chambers. He was a practising barrister from 2014 to 2018, specialising in immigration and asylum law.