BA v Secretary of State for the Home Department [2011] UKUT 36 (IAC), [2011] All ER (D) 193 (Feb)
The factors bearing on the risk on return of dissidents who had engaged in sur place activities fell under four heads. For each factor there was a spectrum of risk. Further, the factors were not exhaustive and might overlap. The first head was the type of sur place activity involved.
The factors to be considered under that head were: (i) what the demonstrators wanted and how they would be characterised by the regime in question; (ii) the role played by the individual and his political profile; (iii) the extent of his participation; and (iv) the extent and nature of the publicity which the demonstration attracted.
The second head was the risk that the person would be identified as engaging in the sur place activity. The factors to be considered under that head were how the regime identified dissidents and what capacity it had to identify individuals.
The third head was the factors that would trigger inquiry/action upon return. Specifically:
