PO (Nigeria) v Secretary of State for the Home Department [2011] EWCA Civ 132, [2011] All ER (D) 240 (Feb)
Whilst it was desirable to identify the evidence considered in a country guidance case, it was not necessary or helpful to set it out in full detail. Moreover, the headnote added by the Asylum & Immigration Tribunal (AIT), reporting committee should adequately reflect the relevant guidance contained in the determination itself. There might be a need to review the current practice to identify the “issue” to which the country guidance was intended to relate.
In the circumstances, there was a current deficiency in guidance available on the ability of the Nigerian authorities to offer shelter to victims of trafficking and the risk of re-trafficking. Until full guidance was produced, paras 191 and 192 of PO (Trafficked Women) Nigeria CG [2009] UKAIT 00046 should stand as interim guidance, pending further consideration by the AIT.
