Asylum Instruction
Exclusion: Article 1F of the Refugee Convention
30 May 2012
Contents
Part 1: Introduction
1.1
Purpose of instruction and enquiries
1.2
Application of this instruction in respect of children and those with children
Part 2: Background to the exclusion clauses
2.1
Text and purpose of Article 1F
2.2
Articles 1D and 1E
2.3
The Article 1F exclusion clauses and the Qualification Directive
2.4
Working with Article 1F – key points
2.5
The Article 1F clauses in summary
Article 1F(a) – crimes against peace, war crimes (including genocide) and crimes against
humanity
Article 1F(b) – Serious non-political crimes
Article 1F(c) – acts contrary to the purposes and principles of the United Nations
2.6
The asylum interview
2.7
Extradition
2.8
Cancellation, cessation and revocation of refugee status
Part 3: The application of all three clauses of Article 1F
3.1
Persecution or prosecution
3.2
Standard of proof
3.3
Issues of complicity and culpability
3.5
Defences
3.6
Persons already punished or pardoned for the Article 1F crime or act
3.7
Section 55 Immigration, Asylum and Nationality Act 2006
3.8
Credibility and “in the alternative” approach
3.9
Extradition
3.10
No balancing test
3.11
Exclusion and family members/dependants
3.12
Cases where Article 1F applies but removal is not possible
3.13
Appeal rights
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Part 4: Application of Article 1F(a) – crimes against peace, war crimes
and crimes against humanity
4.1
Definitions
4.2
Crimes against peace
4.3
War crimes
4.4
Crimes against humanity
4.5
Genocide
Part 5: Application of Article 1F(b) – serious non-political crimes
5.1
Criteria for Article 1F(b) to apply
5.2
Definition of “serious”
5.3
Definition of “non-political”
5.4
Definition of “outside the country of refuge”
Part 6: Application of Article 1F(c) – acts contrary to the purposes and
principles of the United Nations
6.1
The international context of Article 1F(c)
6.2
Applicability of Articles 1F(c) and 1F(b) to acts of terrorism
6.3
Membership of terrorist (including proscribed) organisations
6.4
Actions by non-state persons
Part 7: Cancellation or revocation of refugee status under Article 1F
Change Record
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Part 1: Introduction
1.1
Purpose of instruction and enquiries
This Asylum Instruction provides guidance on the application of Article 1F of the
Convention („the exclusion clauses‟), Article 12 of Council Directive 2004/83/EC („the
Qualification Directive‟) and the corresponding references in the Immigration Rules.
Part 2 provides the background, overview and key points on the use of the exclusion
clauses.
Part 3 provides detailed guidance on the general application of Article 1F.
Parts 4, 5 and 6 provide detailed guidance on the application of each of the individual
sub-clauses, 1F(a), (b) and (c).
Part 7 provides guidance on the cancellation or revocation of refugee status under
Article 1F.
Any enquiries about the application of this guidance should be directed to the NAM+
Protection inbox.
1.2
Application of this guidance in respect of children and those with children
Section 55 of the Borders, Citizenship and Immigration Act 2009 („Section 55‟) requires
the UK Border Agency to carry out its existing functions in a way that takes into account
the need to safeguard and promote the welfare of children in the UK. Caseworkers must
not apply the actions set out in this guidance either to children or to those with children
without having due regard to Section 55. The UK Border Agency instruction „Every Child
Matters - Change for Children„ sets out the key principles to take into account in all
Agency activities.
The statutory duty to children includes the need to demonstrate that asylum applications
and consideration of exclusion issues are dealt with in a timely and sensitive fashion
where children are involved. In accordance with the UN Convention on the Rights of the
Child, the best interests of the child will be a primary consideration (although not
necessarily the only consideration) when making decisions affecting children. This is
most likely to apply in cases where they are dependent on the main applicant (see 3.11
Exclusion and family members/dependants).
Where asylum applications by children are concerned, the application of the exclusion clauses
will be rare and must always be exercised with great caution, in view of the particular
circumstances and vulnerabilities of children. Exclusion on the grounds of crimes or acts
committed while minors will always involve assessing their ability to understand any acts that
they were ordered to undertake and how far they can be held criminally responsible for them. If
there are serious reasons for believing that an individual, whether a child or an adult at the time
of application, has committed acts or crimes contrary to Article 1F, as a minor, for instance while
being compelled to serve with armed forces or an armed group, the individual is more likely to
have been a victim of offences against international law than a perpetrator (see 3.3 Issues of
complicity and culpability).
Specially trained staff deal with asylum applications by minors and will also deal with
those cases where exclusion is being considered in respect of a child applicant. Further
guidance is given in the Asylum Instruction on Processing an asylum application by a
child.
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Part 2: Background to the exclusion provisions
2.1
Text and purpose of Article 1F
The text of Article 1F is as follows;
“The provisions of this Convention shall not apply to any person with respect to
whom there are serious reasons for considering that:
(a) he has committed a crime against peace, a war crime, or a crime against
humanity, as defined in the international instruments drawn up to make
provision in respect of such crimes;
(b) he has committed a serious non-political crime outside the country of
refuge prior to his admission to that country as a refugee;
(c) he has been guilty of acts contrary to the purposes and principles of the
United Nations.”
The purpose of Article 1F is firstly, to deny the benefits of refugee status to certain
persons who could otherwise qualify as refugees but who are undeserving of protection,
because there are „serious reasons for considering‟ that they committed war crimes,
crimes against peace or humanity, serious non-political crimes or acts contrary to the
purposes and principles of the UN, and secondly, to ensure that such persons do not
misuse asylum in order to avoid being held to account for their acts.
Article IF is therefore intended to protect the integrity of the asylum process from abuse.
But it is not a punitive measure and should always be applied responsibly, bearing in
mind the humanitarian character of the Convention and the serious possible
consequences of exclusion for the individual.
The question of whether or not a person falls under the exclusion clauses is part of the
refugee status determination. If after considering exclusion in accordance with Part 3 of
this guidance, there are serious reasons for considering that the subject has committed a
crime or act contrary to Article 1F, asylum must be refused.
2.2
Articles 1D and 1E
The Convention contains two other exclusion clauses, Article 1D and Article 1E. Article
1D is concerned with persons already receiving UN protection, generally those
Palestinian refugees assisted by the United Nations Relief and Works Agency
(UNRWA). Article 1E is concerned with persons not in need of international protection
because they already enjoy a status which corresponds to that of nationals of the
country where they are resident.
2.3
The Article 1F Exclusion Clauses and the Qualification Directive
The UK legislative provisions implement Articles 12 and 14 of the EU Qualification Directive
which sets out the minimum standards for the qualification and status of persons as refugees.
Article 12(2) of the Directive broadly reflects the provisions of Article 1F of the Convention.
In order to be granted asylum, an asylum applicant must satisfy the criteria in paragraph 334 of
the Immigration Rules. Sub-paragraph (ii) states that the applicant “…is a refugee as defined in
regulation 2 of the Refugee or Person in need of International Protection (Qualification)
Regulations 2006” („the 2006 Regulations‟) Qualification Regulations 2006.
Regulation 2 of the 2006 Regulations defines a “refugee” as a person who falls within 1(A) of
the Convention and to whom regulation 7 does not apply.
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Regulation 7 sets out that a person is not a refugee if he or she falls within the scope of Article
1F of the Convention and explains the construction and application of Article 1F(b) in a way
which mirrors the provision of Article 12(2)(b) of the Directive.
Paragraph 339A(vii) of the Immigration Rules also provides that a person‟s grant of asylum will
be revoked or not renewed if the Secretary of State is satisfied that the individual in question
should have been or is excluded from being a refugee in accordance with regulation 7 of the
2006 Regulations. See Part 7: Cancellation or revocation of refugee status under Article 1F
These provisions therefore transpose the relevant provisions of the Qualification Directive into
UK law.
Working with Article 1F – key points
2.4
2.5

Decision-makers should consider both whether an applicant has a well-founded fear of
persecution as defined in Article 1A(2) of the Convention (inclusion) and then whether
that applicant falls to be excluded by virtue of Article 1F (exclusion).

The evidential burden of proof rests with the Secretary of State to show that Article 1F
applies, not for the applicant to show that it does not.

The individual circumstances of the case must be fully explored at interview when
exclusion is an element to the case. The applicant must be given the opportunity to
explain his level of involvement in the crime or act and the motivation or reasoning
behind his alleged actions.

The individual clauses overlap. Reasons for exclusion should normally relate to the most
relevant clause 1F(a), (b), or (c), but it is perfectly possible for more than one clause to
apply, for example, persons who engage in certain acts of terrorism should be
considered for exclusion under Article 1F(b) as well as 1F(c).

In Article 1F the phrase “serious reasons for considering” means what it says:
evidence that is not tenuous or inherently weak or vague, and which supports a case
built around more than mere suspicion or speculation.

There is no requirement for the applicant to have been tried and convicted in order for
Article 1F to apply. Equally, the fact that a person has been convicted and punished for
an offence does not mean that Article 1F will not apply.

If an applicant‟s account of his Article 1F-related activities is not credible, those findings
cannot justify a decision to exclude. But there must also be argument on exclusion to
ensure that should an Immigration Judge believe the applicant and conclude that he is a
refugee, consideration is given to exclusion.

Article 1F cases will often be of keen public and media interest, and can raise sensitive
issues in respect of UK foreign policy. Advice must be submitted to the Chief Executive
before a person who is the subject of extradition proceedings, convicted of a serious
non-political offence, or a fugitive from justice, is granted asylum or another form of leave
such as Humanitarian Protection (HP) or Restricted Leave. It is likely that an individual
excluded from refugee status under Article 1F will also be excluded from Humanitarian
Protection.
The Article 1F clauses in summary:
Article 1F(a) – crimes against peace, war crimes (including genocide) and crimes against
humanity

Invoking Article 1F(a), followed by removal action if appropriate, ensures that the UK‟s
protection is not abused by those who have been involved in:
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o the commission of crimes against peace (ie planning, preparation, initiation or waging
of a war of aggression, or a war in violation of international treaties),
o war crimes (in the context of an internal or international armed conflict), or
o crimes against humanity (the fundamentally inhumane treatment of a population in
the context of a widespread or systematic attack against it).

Further details of potential Article 1F(a) cases can be found in Part 4 of this instruction.
Article 1F(b) – serious non-political crimes

Under Article 1F(b), a crime will be “non-political” if, broadly speaking, it was committed
essentially for personal reasons or gain and no political motives were involved; or where the
crime might have been politically motivated but the crime committed was wholly
disproportionate to the claimed political objective. Under Article 12(2)(b) of the Qualification
Directive, particularly cruel actions, even if committed with an allegedly political objective,
may be classified as serious non-political crimes. Article 1F(b) may therefore include terrorist
crimes.

There is no list of serious crimes in the Convention, and nor is there a list in UK law. Crimes
which attract custodial sentences of 12 months or more are generally to be considered as
serious.

Further details of potential Article 1F(b) cases can be found in Part 5 of this instruction.
Article 1F(c) – acts contrary to the purposes and principles of the United Nations

Acts of terrorism are widely considered contrary to the purposes and principles of the United
Nations, and may potentially fall within Article 1F(c). But they may also fall within Article
1F(b) because acts of terrorism are not necessarily political crimes, or even within Article
1F(a).

Further details of potential Article 1F(c) cases can be found in Part 6 of this instruction.
2.6
The asylum interview

Before undertaking an interview where exclusion is potentially an issue, interviewers must
refer to the detailed guidance in Part 3, section 3.3 Issues of complicity and culpability, as
well as sections 3.4 and 3.5. It is crucial that the individual circumstances of the case are
explored at interview when exclusion is an element to the case. The applicant must be given
an opportunity to explain their level of involvement in the crime or act and the motivation or
reasoning behind their actions. In some cases, a further interview may be needed.

Article 1F may apply, not only in cases where the individual personally committed the act or
crime but also where there are serious reasons for considering that the individual has
voluntarily contributed in a significant way to the organisation or group‟s ability to pursue its
purpose of committing crimes or acts contrary to Article 1F, aware that the assistance will in
fact further that purpose.

An applicant may have a valid defence to a crime or act committed. For example, he may
claim to have been acting under duress and this too must be explored at interview. (See 3.5
Defences).
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2.7
Extradition

Where an individual is subject to an extradition request from a country in which he/she
stands accused or convicted of a criminal offence, the evidence submitted in support of that
request may be enough to show that there are “serious reasons for considering” a crime has
been committed which would fall under Article 1F.

Individual consideration should be given to each case and the Extradition Section of the
Judicial Co-operation Unit should be consulted. For further advice, see 3.9 Extradition.
2.8
Cancellation or revocation of refugee status under Article 1F
Cancellation of refugee status may be appropriate if information comes to light which was not
known about at the time of the original decision – about a crime or acts committed prior, or
subsequent, to arrival in the UK, but previous to the grant of refugee status – which would have
justified the application of Article 1F at the time the person‟s asylum claim was first considered.
Revocation of refugee status should be considered where, subsequent to the grant of asylum,
a person commits a crime or act which falls within the scope of Article 1F(a) or (c).
For further information on withdrawal of refugee status, refer to Part 7: Cancellation or
revocation of refugee status under Article 1F and to the AI on Cancellation, Cessation &
Revocation of Refugee Status.
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Part 3: The application of all three clauses of Article 1F
3.1
Persecution or prosecution
If an applicant is a fugitive from justice rather than fleeing persecution, he would not meet the
refugee definition set out in Article 1A(2) of the Convention (the „inclusion‟ criteria), and his
claim should therefore be rejected.
There may however be situations where an asylum-seeker may be legitimately prosecuted but
has a well-founded fear of persecution, whether in the context of the criminal proceedings or for
unrelated reasons in the country of origin. In such cases, the individual would satisfy the
refugee criteria stipulated in the Convention, provided there is a sufficient link between the
feared persecution and one of the Convention grounds for persecution and that he is not
excludable as undeserving of protection.
The fact that an asylum-seeker is associated with conduct within the scope of Article 1F, or is
under criminal investigation or has been convicted, either in his/her country of origin or in a host
country may raise exclusion considerations, but it does not mean that the exclusion clauses will
automatically apply. The facts must be considered against the stringent tests set out in Article
1F and explained in more detail below.
3.2
Standard of proof
Article 1F applies if “there are serious reasons for considering” that the person concerned has
committed certain crimes or acts. The phrase “serious reasons for considering” should be given
its natural (common sense) meaning.
“Serious reasons for considering” is not a level of proof equivalent to that needed for a criminal
conviction (“beyond reasonable doubt”). The Supreme Court decision in the case of JS (Sri
Lanka) in March 2010 confirmed that the phrase sets a standard above mere suspicion and has
to be treated as meaning what it says. The Court said that ““considering” approximates rather to
“believing” than to “suspecting””. The evidence should not be tenuous or inherently weak or
vague, and should support a case built around more than suspicion.
The evidential burden of proof rests with the Secretary of State to show that Article 1F applies,
not for the applicant to show that it does not.
Whichever clauses of Article 1F apply, the person does not have to have been prosecuted or
convicted of any offence in any country. However, evidence of a conviction will usually provide
serious reasons for considering that the person has committed the crime and case owners will
not normally need to examine at length the evidential basis for the conviction. But they should
keep in mind the possibility that an asylum claimant who was a known opponent of his or her
country‟s government could be the victim of false charges and that a criminal prosecution or
conviction in the country of origin may in fact constitute evidence of persecution, especially in
countries where the standards of judicial fairness fall well short of internationally accepted
standards.
Equally, evidence of the acquittal of a person accused of a crime does not necessarily mean
that exclusion is inappropriate. Each case should be considered on its own merits.
In connection with the standard of proof, if information about a possible crime comes to light as
a result of an extradition request, see 3.9 Extradition.
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3.3
Issues of complicity and culpability
All three clauses of Article 1F will raise issues about the nature of a person‟s participation in a
possible crime or act. The issue of complicity is of vital importance in assessing the extent to
which the individual has knowingly engaged in activities which may bring them within the scope
of Article 1F.
Exclusion under 1F is not dependent upon being part of an organisation. At the same time, it is
well established that those who should be held accountable for war crimes (or other acts
contrary to Article 1F) are not solely the people who directly commit the offences.
However, membership of, or employment in, an organisation which uses violence, or the threat
of violence, as a means to achieve its political or criminal objectives is not enough on its own to
make a person guilty of an international crime, and is not sufficient to justify exclusion from
refugee status. The individual member of a political group, for example, which may not
necessarily be in control over acts of violence committed by militant wings, cannot be held
automatically to account for those actions.
Moreover, the nature of some groups‟ violent conduct may have evolved, so the individual‟s
membership must be examined in the context of the organisation‟s behaviour at the time when
he was part of the group. Defences to exclusion, such as duress/coercion, also need to be
considered (see below at 3.5).
Depending on the circumstances, therefore, a person may incur individual responsibility for
excludable crimes:




by personally perpetrating excludable crimes;
for crimes committed by others, either by provoking others to commit such crimes (for
example, through planning, inciting, ordering, soliciting or inducing the commission of the
crime); or
by significantly aiding or abetting the planning, preparation or execution of the crime or
participating in a joint criminal enterprise; and/or
by making a substantial contribution to the commission of a crime by others, knowing
that his/her acts facilitated the criminal conduct (e.g. by controlling the funds of an
organisation known to be dedicated to achieving its aims through violent means or
organising the physical or logistical support necessary to enable a terrorist group to
operate).
This last point was clarified in the judgment of the Supreme Court in JS (Sri Lanka) in March
2010. It said that the exclusion clauses will apply if there are serious reasons for considering
that the individual has voluntarily contributed in a significant way to the organisation‟s ability to
pursue its purpose of committing war crimes, aware that the assistance will in fact further that
purpose. If the person was aware that in the ordinary course of events a particular
consequence would follow from his actions, he would be taken to have acted with both
knowledge and intent.
Although its judgment related to Article 1F(a) cases, the test articulated on this issue by the
Supreme Court extends to Article 1F generally (i.e. crimes and acts other than war crimes).
The Supreme Court said that it was preferable to focus from the outset on what ultimately had to
be the determining factors in any case, principally (in no particular order):

the nature and (potentially of some importance) the size of the organisation and particularly
that part of it with which the asylum-seeker was himself most directly concerned,

whether and, if so, by whom the organisation was proscribed,

how the asylum-seeker came to be recruited,
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
the length of time he remained in the organisation and what, if any, opportunities he had to
leave it,

his position, rank, standing and influence in the organisation,

his knowledge of the organisation‟s war crimes activities, and

his own personal involvement and role in the organisation including particularly whatever
contribution he made towards the commission of war crimes.
3.4
Establishing individual responsibility: intent and knowledge requirements
Once it has been determined that there is good reason to believe the individual committed the
act or crime or significantly contributed to it, and is potentially excludable under one or more of
the exclusion clauses of Article 1F, the case owner must next assess the individual‟s state of
mind at the time of the act or crime. It is not enough to establish that the individual committed or
participated in the act; it should also be established that he had the requisite understanding and
intention at the time that he participated in or committed that act. The asylum interview must
investigate these issues thoroughly.
To fulfil this second element of the individual responsibility requirement (the „mens rea‟ element:
literally „guilty mind‟, one of the necessary elements of a crime in criminal law), the individual
must have acted with both „intent‟ and „knowledge‟, i.e. the person intended to engage in the
conduct at issue or to bring about a particular consequence („intent‟), and was aware that
certain circumstances existed or knew that certain consequences would follow in the ordinary
course of events („knowledge‟). In other words, they knew what they were doing and its context.
Where the person concerned is regarded (on the available evidence) as not having possessed
the required understanding and intention, due to, for example, immaturity (see 1.2 Application of
this guidance in respect of children), insanity, mental handicap, involuntary intoxication, a
fundamental aspect of the excludable act is missing and no individual responsibility arises for
the act in question. The individual would not fall within Article 1F and should not be excluded.
If the case owner considers that the individual had the necessary „mens rea‟ to be held
individually responsible for the excludable act, the case owner must then consider whether one
of the defences is applicable before finally determining whether or not the individual is
excludable.
3.5
Defences
An exclusion analysis also requires an assessment of any other circumstances which may
negate individual responsibility and give rise to a valid defence, thus exonerating him/her from
individual responsibility for his/her acts. Defences which may be valid, depending on the
circumstances, are (i) superior orders, (ii) coercion/duress or (iii) self-defence/defence of others.
A key issue will be the extent to which the individual could reasonably exercise freedom of
choice not to take part or assist the criminal act. For example, a child conscript in an army is
more likely to have been coerced into service and forced to commit war crimes than an adult.
Gender or cultural issues may also be relevant.
(i) Superior orders
A commonly-invoked defence is that of “superior orders” or coercion by higher authorities,
although it is an established principle of law that the defence of superior orders does not
absolve individuals of blame. The defence of superior orders will only apply if the individual in
question was under a legal obligation to obey the order in question, was unaware that the order
was unlawful, and the order itself was not manifestly unlawful (the latter being deemed so in all
cases of genocide or crimes against humanity).
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(ii) Duress/coercion
The defence of duress only applies if the incriminating act committed by the individual resulted
from a threat of imminent death or of serious bodily harm against that individual or someone
else, and the individual acted necessarily and reasonably to avoid this threat, provided that the
individual did not knowingly intend to cause a greater harm than the one to be thus avoided.
There are, therefore, stringent conditions to be met for the defence of duress to arise. Where
duress is pleaded by an individual who acted on the command of other persons, consideration
should be given as to whether the individual could reasonably have simply left the organisation,
and why he did not do so earlier if it was clear that the situation in question would arise. Each
case should be considered on its own facts. The consequences of desertion plus the
forseeability of being put under pressure to commit certain acts are relevant factors.
(iii) Self-defence; defence of other persons or property
The use of reasonable and necessary force to defend oneself may be a valid defence. Similarly,
reasonable and proportionate action to defend another person or property which is essential for
the survival of the person or another person, against an imminent and unlawful use of force,
may also provide a defence to criminal responsibility under certain circumstances.
3.6
Persons already punished or pardoned for the Article 1F crime or act
There may be cases where the serious reasons for considering that an applicant has committed
an Article 1F crime or act are that prosecution took place and the person was convicted of the
offence. Such cases are probably most likely to arise in relation to Article 1F(b) – serious nonpolitical crimes committed outside the country of refuge.
The Convention does not exempt someone from exclusion on the basis that they have already
been punished for their crime or act. Nevertheless, the circumstances of conviction and
punishment should be taken into account in order to establish, for example, whether that was
for political or other Convention reasons.
3.7
Section 55 Immigration, Asylum and Nationality Act 2006
Where Article 1F applies, an applicant cannot be granted asylum and the application must be
refused. To ensure that this issue is fully considered at appeal, section 55 of the 2006 Act
provides that the Secretary of State can issue a certificate to that effect.
The Tribunal or the Special Immigration Appeals Commission (SIAC) must then begin
substantive deliberations on any asylum appeal by considering the certificate. If the Tribunal or
SIAC agree with the statements in the certificate, they should consider exclusion first and if they
agree that the person is excluded they need not consider whether Article 1A of the Convention
applies. Where the person is in the UK and asylum is being refused or refugee status is being
cancelled or revoked because Article 1F applies, a section 55 certificate should normally be
issued.
3.8
Credibility and “in the alternative” approach
Cases will arise where an individual‟s claims concerning potential Article 1F crimes or acts are
not credible but were those claims true, they would amount to serious crimes or acts within the
scope of Article 1F.
Accounts which are not credible do not provide “serious reasons for considering that” the
individual has committed the crime or act which would bring him within Article 1F. If the
individual does not have protection needs, the application should be refused without recourse to
exclusion, and these cases should not be certified under section 55 of the 2006 Act. However,
following the assessment of credibility and consideration under Article 1A(2), the case owner
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should set out briefly why, if the relevant statements in the claim were true, the individual should
be excluded under Article 1F.
3.9
Extradition
The Convention does not shield refugees or asylum-seekers who have engaged in criminal
conduct from prosecution for their acts, nor does international refugee law preclude extradition
in all circumstances. Nevertheless, where an asylum application has been made on the basis of
a well founded fear of persecution in the state requesting extradition, the claim must be finally
determined before extradition can take place.
For an extradition request to be made to the UK and acted upon, there will usually (but not
always) be a pre-existing extradition arrangement in place between the countries concerned –
that is to say, a bilateral treaty or a multilateral agreement to which both countries are parties.
The existence of extradition proceedings is relevant to the consideration of exclusion because
the evidence submitted in support of the extradition request may provide a basis for exclusion
from the protection of the Convention. The fact that an asylum seeker is associated with
conduct within the scope of Article 1F may raise exclusion considerations, but it does not
automatically lead to an application of the exclusion clauses. Careful consideration must be
given as to the nature of the evidence submitted and regard must be had to the fact that the
process of extradition is not a trial of guilt or innocence.
As to the standard of evidence provided in support of an extradition request, the nature of the
UK‟s extradition relations is such that while some of our extradition partners are required to
submit evidence which satisfies the prima facie evidential standard (that is, evidence which if
unchallenged would establish a case on which the person could be convicted in the UK), certain
other countries (currently over 40) do not have to do so. Either way, however, where an
accused person is the subject of an extradition request consideration should be given as to
whether the evidence or information submitted in support of the request is sufficient to show that
there are “serious reasons for considering” that a crime has been committed, such as to bring
that person within Article 1F of the Convention. In all cases, consideration should be given to
the specific facts of the particular case.
It is not the function of the extradition process in the UK to test the guilt or innocence of an
individual who stands accused abroad. That is a matter for the ordinary criminal courts of the
requesting State, if extradition takes place. The task of the UK courts is to determine whether
any of the statutory barriers to surrender set out in the Extradition Act 2003 operate to prevent
the person from being extradited. Whether the courts decide that any of these statutory barriers
to extradition applies is not determinative of whether or not exclusion is justified. To illustrate:
the fact that the Judge might discharge the person on “non-evidential grounds” (say, to do with
human rights or the passage of time), may imply nothing at all about the evidence or information
in the extradition request as to the person‟s conduct. It follows that care will need to be taken in
each case to determine whether Article 1F applies.
Extradition requests involving asylum seekers or refugees are not likely to arise very frequently,
but when they do, the Judicial Cooperation Unit (JCU) must be consulted before a decision is
reached on the asylum application. This is not to ensure that JCU agrees with the decision but
to check that the extradition process and evidence has been understood by the UK Border
Agency decision-maker.
In view of the importance of maintaining the integrity of the extradition process, the Chief
Executive (and the Minister for Immigration, in cases where there is public interest or finely
balanced evidence) should be consulted:

where the individual otherwise qualifies for asylum or Humanitarian Protection (HP) and
the evidence provided by the extradition request is not sufficient to justify exclusion
under Article 1F
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
before a person who is the subject of an extradition request or who claims to be a
fugitive from justice is granted asylum or other form of leave such as HP or Restricted
Leave.
See also Part 7: Cancellation or revocation of refugee status under Article 1F and the AI on
cancellation, cessation and revocation of refugee status where the person against whom the
extradition request is made has already been granted asylum.
3.10
No balancing test
Article 1F of the Convention provides that a person shall be excluded from its provisions where
the conditions set out in that Article are met. In considering whether or not Article 1F applies in
the case of a person who appears to have a well-founded fear of persecution, there should be
no weighing up (“balancing”, or consideration of „proportionality‟) of the extent of persecution
feared against the gravity of the Article 1F crime or act. Section 34 of the Anti-Terrorism, Crime
and Security Act 2001 (ATCS Act) explicitly provides that there is to be no such balancing test.
Article 12(2) of the Qualification Directive states that a person is excluded from being a refugee
where the provisions of Article 1F apply. Furthermore, in a judgment of the Court of Justice of
the European Union („the CJEU‟) B and Others C-57/09 and C-101/09 on 9 November 2010, the
CJEU found, inter alia, that exclusion from refugee status under Article 12(2)(b) or (c) of the
Directive was not conditional on a fresh assessment of proportionality in relation to the particular
case providing the decision-maker had already assessed the seriousness of the acts
committed by the individual and taken into account all the circumstances.
The risk of mistreatment a person may face if returned to their country of origin or elsewhere will
need to be considered in the context of whether that person‟s removal would be a breach of the
UK‟s obligations under the European Convention on Human Rights (ECHR). See section 3.11
below.
3.11
Cases where Article 1F applies but removal is not possible
This situation is most likely to arise due to human rights considerations.
These considerations must be addressed in a case involving an excluded person, just as in any
other case. Article 3 of the ECHR is particularly important, in that it prevents removal of anyone
if there are substantial grounds for believing that their removal would expose them to a real risk
of torture or inhuman or degrading treatment or punishment. This applies irrespective of the
crimes or acts that a person has committed or the danger they pose to the UK. In limited
circumstances, it is possible that removal may breach Articles of the ECHR other than Article 3.
These also need to be considered.
Every effort should be made, consistent with our international obligations, to secure the removal
of person to whom Article 1F applies, but where this is not possible, a grant of Restricted Leave
(RL) may be appropriate. In such cases, the Chief Executive must first be consulted by way of
submission before granting leave and case owners must familiarise themselves with the policy
guidance on Restricted Leave which first came into effect on 2 September 2011.
3.12
Exclusion and family members/dependants
If there are family members seeking to remain in the UK as dependants of an applicant whose
claim for asylum is refused partly or wholly in reliance on Article 1F, the applications from those
family members should also be refused as dependants of the individual to be excluded.
However, dependants may apply for asylum in their own right and such claims should be
considered on their merits. They cannot be excluded from the protection of the Convention
simply because of the actions of the principal applicant. Those claims to refugee status could
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succeed even where the fear of persecution is a result of the relationship to the excluded
relative.
If the dependant‟s own asylum claim meets the requirements for inclusion under Article 1A and
they are not excluded from protection, they should be granted asylum. However, where a
dependant has previously been excluded from the protection of the Convention as a result of
their own actions, they should not be given leave in line with a principal applicant.
Situations might also arise where a person seeking to remain as the dependant of an asylum
seeker or refugee appears to have committed a crime or act which, had they been seeking
asylum in their own right, would make them a potential candidate for exclusion under Article 1F.
In such a case, consideration should be given to whether the conditions of Article 1F are met. If
they are, the application to enter or remain as a dependant should be refused.
Where it is proposed to remove the principal applicant (who has been excluded) but to allow a
dependant to stay (or where it is proposed to remove a dependant covered by the exclusion
clauses but not to remove the principal applicant who is not excluded), consideration will need
to be given to whether removal of the excluded person would be a breach of Article 8 ECHR
(right to respect for family life).
Under Article 8(2) of the ECHR, interference in an existing family life is permissible
where it is “in accordance with the law”, pursues a legitimate aim (e.g. immigration
control) and is proportionate to that aim. Where a crime has been committed it may be
that any interference with family life can be justified on the grounds that it is necessary
and proportionate for immigration control or to prevent crime or disorder (amongst other
possible legitimate aims). However, each case must be treated on its individual facts and
merits.
In accordance with Section 55 of the 2009 Act (see 1.2 Application of this guidance in
respect of children and those with children), the best interests of the child will be a
primary consideration (although not necessarily the only consideration) when making
decisions affecting children.
3.13
Appeal rights
Where an asylum claim is refused partly or wholly on the ground that Article 1F applies, the
same appeal rights apply as in a case where the claim has been refused without any reliance
on these exclusion grounds and an immigration decision has been taken under section 82 NIA
or where section 83 NIA applies. See the AI on implementing substantive decisions.
However, where it is certified that section 55 of the IAN Act 2006 applies, the appellate authority
will commence its deliberations by considering the Secretary of State‟s certificate (to the effect
that the individual is excluded from the 1951 Convention by virtue of Article 1F).
If the certificate is upheld, the appeal should be dismissed to the extent that it relies on asylum
grounds, though any ECHR considerations raised in the appeal will still have to be taken into
account. National security cases and certain other types of cases may be certified under section
97 of the NIA. In those circumstances, the appeal lies to the Special Immigration Appeals
Commission and not to the Tribunal.
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Part 4: Application of Article 1F(a) – crimes against peace, war crimes
and crimes against humanity
“The provisions of this Convention shall not apply to any person with respect to whom
there are serious reasons for considering that:
(a) he has committed a crime against peace, a war crime, or a crime against
humanity, as defined in the international instruments drawn up to make
provision in respect of such crimes;”
4.1
Definitions
There is no one single set of definitions of what constitutes a war crime, crime against humanity
or genocide for the purposes of the Convention, but detailed definitions of “war crimes” and
“crimes against humanity” are contained in Articles 6, 7 and 8 of the International Criminal Court
(Rome) Statute, and have been incorporated into UK law by the International Criminal Court
(ICC) Act 2001. Those definitions are summarised below. The Rome Statute established the
International Criminal Court (the ICC) in The Hague, Netherlands as a permanent institution
with the power to exercise its jurisdiction over persons for the most serious crimes of
international concern. Article 1F(a) can be invoked irrespective of the location where the alleged
crime was committed.
4.2
Crimes against peace
A crime against peace has been defined as including planning, preparation, initiation or waging
of a war of aggression, or a war in violation of international treaties, agreements or assurances
(see Annex V of the UNHCR Handbook). The crime of aggression has now (by resolution of 11
June 2010) been defined in Article 8 (bis) of the Rome Statute as: “the planning, preparation,
initiation or execution, by a person in a position effectively to exercise control over or to direct
the political or military action of a State, of an act of aggression which by its character, gravity
and scale, constitutes a manifest violation of the Charter of the United Nations”.
4.3
War crimes
A war crime involves the violation of international humanitarian law or the laws of armed conflict.
They constitute violations of the laws and customs of war which entail individual criminal
responsibility under international law, whether on the basis of a treaty or under customary
international law. Likewise, only acts which are connected to an armed conflict may constitute
„war crimes‟. Such violations may include murder or ill-treatment of civilian populations or of
prisoners of war, the killing of hostages, or any wanton destruction of cities, towns or villages, or
a deliberate policy of devastation that is not justified by any military necessity.
4.4
Crimes against humanity
Crimes against humanity differ from war crimes (which occur only during times of armed
conflict) in that they can be committed at any time. However, in times of armed conflict a single
act could constitute both a war crime and a crime against humanity.
In order to amount to a crime against humanity, the particular crimes (such as murder or rape)
must have been committed as part of a widespread or systematic attack directed against a
civilian population, with knowledge of the attack. Inhumane treatment of this kind may often be
grounded in political, racial, religious or other prejudice. Such treatment would include murder,
enslavement, torture, deportation or forcible transfer of a population and enforced
disappearance of persons.
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A policy of committing acts against a civilian population does not have to have been formally
written down or recorded, but there should be evidence of a deliberate campaign against, or
general attack on, a civilian population, rather than simply a series of random violent acts.
A single act might qualify as a crime against humanity, provided it was linked to a general policy
to attack a civilian population. Even if not constituting a crime against humanity, it should also
be considered as a serious non-political crime for the purposes of Article 1F(b).
4.5
Genocide
Genocide is a sub-section of Crimes against Humanity. It is expressly included within the
jurisdiction of the ICC.
The term “genocide” would include crimes such as murder, causing serious bodily or mental
harm, or imposing measures intended to prevent births within a group, if they are committed
with intent to destroy, in whole or in part, a national, ethnic, racial or religious group.
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Part 5: Application of Article 1F(b) – serious non-political crimes
“The provisions of this Convention shall not apply to any person with respect to whom
there are serious reasons for considering that:
(b) he has committed a serious non-political crime outside the country of refuge
prior to his admission to that country as a refugee;
5.1
Criteria for Article 1F(b) to apply
The four criteria that must be satisfied are:

There must be serious reasons for considering that the individual has committed a criminal
offence in another country

The offence has to be serious

The offence has to be non–political

The offence has to have been committed before coming to the United Kingdom
5.2
Definition of “serious” crime
The Convention does not list offences which are to be treated as “serious” crimes.
Article 12(2)(b) of the Qualification Directive reflects the provisions of Article 1F(b) of the
Convention and expands on the definition thus:
“(b) he or she has committed a serious non-political crime outside the country of refuge prior to
his or her admission as a refugee; which means the time of issuing a residence permit based on
the granting of refugee status; particularly cruel actions, even if committed with an allegedly
political objective, may be classified as serious non-political crimes;”
The UNHCR Handbook (paragraph 155) states that “a „serious‟ crime must be a capital
crime” (ie punishable by the death penalty) or “a very grave punishable act”.
However, as a guide as to what level of offending constitutes “serious”, the UK Border
Agency uses the definition of „particularly serious‟ in section 72 Nationality, Immigration
and Asylum Act 2002 („Section 72‟). This provides that a particularly serious crime is
one which either attracted a custodial sentence of two years or more OR, where the
offence is committed outside of the UK, could have attracted a custodial sentence of two
years or more had the offence been committed in the UK.
However, given that the Article 1F(b) requirement states exclusion will be merited following a
„serious‟ crime, as opposed to „particularly serious‟, it may be appropriate to regard a crime for
which a custodial sentence of 12 months or more upon conviction might be expected (if that
crime had been tried in the United Kingdom) as a “serious crime”. This is also in keeping with
the provision for automatic deportation (section 32(2) of the UK Borders Act).
It is obviously difficult to predict what sentence might be passed in relation to a particular
offence committed abroad. The likely sentence is therefore less important than the nature of the
crime, the actual harm inflicted, and whether most jurisdictions would consider it a serious
crime. Examples of „serious‟ crimes include murder, rape, arson, and armed robbery. Other
offences which might be regarded as „serious‟ include those which are accompanied by the use
of deadly weapons, involve serious injury to persons, or if there is evidence of serious habitual
criminal conduct. But other crimes, though not accompanied by violence, such as large-scale
fraud, may also be regarded as „serious‟ for the purposes of Article 1F(b).
5.3
Definition of “non-political”
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With regard to the determination of what constitutes a „non-political crime‟, regard needs to be
given first to the nature and purpose of the act, namely, whether or not it was committed for
genuine political motives and not merely for personal reasons or gain. Where no clear link exists
between the crime and its alleged political objective or when the act in question is
disproportionate to the alleged political objective, non-political motives predominate and 1F(b) is
appropriate. Thus, the motive, context, methods, and proportionality of a crime to its objectives
are relevant factors in assessing its nature. Acts that are grossly out of proportion to any
claimed political objectives would not be „political‟.
Article 12(2)(b) of the Qualification Directive provides interpretative guidance on Article 1F(b) of
the Convention. It states that a “particularly cruel action” will be held to be a “serious nonpolitical crime” for the purpose of Article 1F(b), even if it is committed with an allegedly political
objective”.
In T v Secretary of State for the Home Department (SSHD) (1996), the House of Lords held
that Article 1F(b) applied to a refugee who had been involved in terrorist acts which killed
innocent people, and rejected the argument that the acts were “political” for the purposes of
Article 1F(b). Persons who engage in certain acts of terrorism may therefore be excluded under
Article 1F(b), as terrorist acts which are wholly disproportionate to any political motive will often
be “non-political”.
In T v SSHD, the following definition of a political crime was used:
“A crime is a political crime for the purposes of Article 1F(b) of the 1951 Convention
if and only if:
(1) it is committed for a political purpose, that is to say with the object of
overthrowing or subverting or changing the government of a state or inducing it to
change its policy; and
(2) there is a sufficiently close and direct link between the crime and the alleged
political purpose.
In determining whether such a link exists, the court will bear in mind the means
used to achieve the political end, and will have particular regard to whether the
crime was aimed at a military or governmental target, on the one hand, or a civilian
target on the other, and in either event whether it was likely to involve the
indiscriminate killing or injuring of members of the public.”
Consistent with the reasoning in T v SSHD, the commission of crimes such as murder, rape and
serious assault, or other violent acts which result in indiscriminate harm or death to the public,
will usually fail to establish a sufficient link to the achievement to a political objective and should
be considered to be “non-political” crimes for the purposes of Article 1F(b). A link may however
be established to a political crime if such methods are used against specific targets that are
political in nature (e.g. government representatives etc) and are committed for political motives.
5.4
Definition of “outside the country of refuge”
When transposing Article 1F(b) into EU law, Article 12(2)(b) of the Qualification Directive
provides that a person is excluded from being a refugee where there are serious reasons for
considering that he or she has committed a serious non-political crime outside the country of
refuge prior to his or her admission as a refugee; “which means the time of issuing a residence
permit based on the granting of refugee status”.
In transposing Article 12(2)(b) into UK law, Regulation 7(2)(b) of the 2006 Regulations sets out
that the reference to the crime being committed outside the country of refuge prior to his
admission as a refugee shall be taken to mean the time “up to and including the day on which a
residence permit is issued”. For the purposes of this instruction, “admission to the UK as a
refugee” therefore refers to any point up to the point where a residence permit is formally issued
to the subject.
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In rare cases it could happen that a crime, such as conspiracy to import drugs, was committed
both overseas – before the asylum seeker came to the UK – and continued in the UK after
arrival. Continuous crimes such as this can therefore be considered as “being committed
outside the country of refuge” for the purposes of Article 1F(b).
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Part 6: Application of Article 1F(c) – acts contrary to the purposes and
principles of the United Nations
“The provisions of this Convention shall not apply to any person with respect to whom
there are serious reasons for considering that:
(c) he has been guilty of acts contrary to the purposes and principles of the United
Nations.”
6.1
The international context of Article 1F(c)
The purposes and principles of the United Nations are set out in the Preamble and Articles 1
and 2 of the Charter of the United Nations.
Article 1 of the United Nations‟ Charter lists four purposes, namely to:

maintain international peace and security;

develop friendly and mutually respectful relations among nations;

achieve international co-operation in solving socio-economic and cultural problems,
and in promoting respect for human rights; and

serve as a centre for harmonising actions directed to these ends.
Member states are bound together by these purposes, through a series of principles set out in
Article 2 of the Charter. These include:

respect for sovereign equality;

good faith fulfilment of obligations;

peaceful settlement of disputes;

refraining from the use of force against the territorial integrity or political independence
of another state; and

promotion of the work of the United Nations.
6.2 Applicability of Articles 1F(c) and 1F(b) to acts of terrorism
Acts of terrorism are widely considered contrary to the purposes and principles of the United
Nations, as set out in the United Nations Security Council Resolutions relating to measures
combating terrorism (United Nations Security Council Resolutions 1373 and 1377 which declare
that the “acts, methods and practices of terrorism are contrary to the purposes and principles of
the United Nations” and that “knowingly financing, planning and inciting terrorist acts are also
contrary to the purposes and principles of the United Nations”.
In Security Council Resolution 1566 (October 2004), the Council condemned terrorism as one
of the most serious threats to peace and security, and called on countries to prosecute or
extradite anyone supporting terrorist acts or participating in the planning of such schemes. The
text called on countries to prevent and punish “criminal acts, including against civilians,
committed with the intent to cause death or serious bodily injury, or taking of hostages, with the
purpose to provoke a state of terror in the general public or in a group of persons or particular
persons, intimidate a population or compel a government or an international organization to do
or to abstain from doing any act” where such acts constitute offences as defined in international
conventions and protocols relating to terrorism.
In addition, Security Council Resolution 1624 (September 2005) also called upon States to
adopt measures, consistent with international obligations, to prohibit by law incitement to
commit a terrorist act or acts and to deny safe haven to those for whom credible evidence exists
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that they have been guilty of such conduct. The resolution also repudiated attempts at the
justification or glorification of terrorist acts that may incite further terrorist acts.
In UK law, section 54 Immigration, Asylum and Nationality Act 2006 provides that acts contrary
to the purposes and principles of the United Nations shall be taken as including, in particular:

Acts of committing, preparing or instigating terrorism (whether or not the acts amount to an
actual or inchoate offence) and,

Acts of encouraging or inducing others to commit, prepare or instigate terrorism (whether or
not the acts amount to an actual or inchoate offence).
The section then defines „terrorism‟ for the purpose of interpreting Article 1F(c) in UK law as
having the meaning given by Section 1 of the Terrorism Act 2000 (as amended by the Terrorism
Act 2006).
Persons who engage in certain acts of terrorism must also be considered for exclusion under
Article 1F(b) as terrorist acts will often be “non-political” (see 5.3 Definition of “non-political”)
because they are wholly disproportionate to any political motive. For an act of terrorism to fall
also within Article 1F(a), it would have to be determined that such an act constituted a „crime
against peace‟, „war crime‟ or „crime against humanity‟.
6.3
Membership of terrorist (including proscribed) organisations
An asylum applicant may claim at interview or in correspondence that they are a member or an
active supporter of a terrorist organisation or any other proscribed organisation.
Proscribed organisations are listed on Home Office website and in Schedule 2 to 2000 Act, as
amended.
Claims of this kind may sometimes be false and intended to enhance an applicant‟s asylum
claim. Where, however, the applicant makes a credible claim of membership, it will be
necessary to consider whether the applicant can be held individually responsible for committing
terrorist acts or serious crimes. The fact that an individual may be on a list of terrorist suspects
or be a member of an organisation designated as terrorist does not mean that the exclusion
clauses are automatically assumed to apply but may be evidence of such involvement.
Adapting the test set down by JS (Sri Lanka) to terrorist cases, the question would be as
follows: has the individual voluntarily contributed in a significant way to the organisation‟s ability
to pursue its purpose of committing acts of terrorism/serious crime(s), aware that the assistance
will in fact further that purpose? See 3.3 Issues of complicity and culpability.
Case owners should therefore take these factors into account when making a decision on
whether members of a proscribed organisation can be considered to fall within 1F(c). Case
owners should consider exclusion particularly carefully where there is evidence that an
individual has been convicted of an offence under section 11 of the Terrorism Act 2000
(belonging, or professing to belong, to a proscribed organisation).
6.4
Actions by non-State persons
Article 1F(c) applies to anyone who commits an act which is contrary to the purposes and
principles of the United Nations. That person does not have to be acting on behalf of a State or
as part of an organisation. Individuals acting in a non-State capacity should be excluded under
1F(c) where their actions merit it.
UNSCR 1377 reinforces this view by stating the UN Security Council‟s “unequivocal
condemnation of all acts, methods and practices of terrorism as criminal and unjustifiable,
regardless of their motivation, in all their forms and manifestations, wherever and by whomever
committed”.
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In the case of KK [KK (Article 1F(c)) (Turkey) [2004] UKIAT 00101], the Immigration Appeals
Tribunal explicitly rejected the argument that only those in power or a state or state like entity
should be covered by Article 1F(c).
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Part 7: Cancellation or revocation of refugee status under Article 1F
There may be occasions where a person has been recognised as a refugee and information
subsequently comes to light which provides serious reasons for considering that the person
should have been excluded from protection by virtue of Article 1F. Article 14(3)(a) of the
Qualification Directive provides for the “revocation of, ending of or refusal to renew refugee
status” where “he or she should have been or is excluded from being a refugee in accordance
with Article 12”.
Paragraph 339A(vii) of the Immigration Rules provides that a person‟s grant of asylum will be
revoked or not renewed if the Secretary of State is satisfied that the individual in question
should have been or is excluded from being a refugee in accordance with regulation 7 of the
2006 Regulations.
In this situation it is possible to cancel that person‟s refugee status on the basis that Article 1F
applies. Although there is nothing in the Convention itself which addresses this point (Article 1C
of the Convention is concerned with a different matter – cessation of refugee status),
paragraphs 117 and 141 of the UNHCR Handbook acknowledge that refugee status might be
cancelled in these circumstances.
There is a second situation in which it may be appropriate to take away a person‟s refugee
status. In this situation the term “revocation” is used rather than “cancellation”. That is where,
subsequent to the grant of asylum, a person commits a crime or acts in a way which falls within
the scope of Article 1F (a) or (c). The possibility of revocation cannot arise in respect of Article
1F(b) since the crime would not have been committed prior to that person‟s admission to the UK
as a refugee.
However, as there are no geographical or time limitations on Article 1F(a) or 1F(c) crimes/acts,
it would be appropriate to consider revocation of refugee status in the event that a crime or act
meeting the requirements of those clauses was committed after refugee status had been
granted.
For further information on cancellation / revocation of refugee status, refer to the AI on
cancellation, cessation and revocation of refugee status.
Cancellation / revocation of refugee status does not of itself affect a person‟s immigration status
and does not therefore attract any statutory appeal right. In practice, however, cancellation /
revocation will normally result in curtailment of any extant leave or is likely to result in an
attempt to remove the person in question. That action (i.e. the decision to curtail leave or to
deport) may trigger appeal rights.
If removal is not possible (e.g. because of the UK‟s obligations under Article 3 of the ECHR),
action to revoke a person‟s indefinite leave to enter or remain in accordance with the provisions
in section 76 of the NIA Act 2002 may be appropriate. A decision to revoke leave under this
section also attracts a right of appeal under section 82 NIA Act 2002.
For further information on section 76 NIA Act 2002, refer to the AI on revocation of indefinite
leave.
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Change Record
Version
Author(s)
Date
Change Reference(s)
1.0
RE (APU)
01/10/2006
2.0
MS (AOPU)
14/04/2008
Updated
3.0
BN (OPPI)
11/11/2008
Updated Branding
4.0
JL
27/10/2009
Children‟s Duty Paragraph Added
5.0
BG (NAM+)
28/05/2012
Review post JS (Sri Lanka) and other case law
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