Oral disclosure at a Tribunal hearing of the substance of adverse country information about document fraud satisfies both procedural fairness obligations and s 424A(1) of the Migration Act, even without written notice under s 441A. The Tribunal is not required to disclose its preliminary evaluative conclusions about the authenticity of documents. The question whether general country information about document fraud falls within s 424A(1)(a) notwithstanding s 424A(3)(a) was left open.
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