Material raised only in the Refugees Convention context will not automatically be treated as raising a complementary protection claim, particularly where the claimant is professionally represented; asylum seekers' representatives must expressly articulate complementary protection claims separately from Refugees Convention claims.
The full text is available to signed-in members, including the 101 later cases that cite this judgment.
5 of the 101 citing cases carry a classified treatment. How each court treated it is available to signed-in members.