FK (FGM – Risk and Relocation ) Kenya  UKAIT 00041
Date of hearing: 23 October 2006
Date Determination notified: 04 April 2007
|Secretary of State for the Home Department||RESPONDENT|
(1) Women in Kenya belonging to those ethnic groups (or sub-groups) where Female Genital Mutilation is practised are a particular social group for the purposes of the 1951 Geneva Convention. Uncircumcised women in Kenya are not as such at real risk of FGM. A woman will be at real risk in her own home area if she comes from an ethnic group (or sub-group) where FGM is practised and the credible evidence shows she is reasonably likely to be required by her parents or others in a position of power and influence over her to undergo FGM.
(2) Internal relocation will be available in Kenya to a woman who is at real risk of FGM in her home area if the evidence shows; (i) she is not reasonably likely to encounter anyone in the place of relocation who would be in a position of power and influence over her and who would use that power and influence to require her to undergo FGM; and (ii) she can reasonably be expected to live in that place, having regard to the general circumstances prevailing in it and to the personal circumstances of the appellant (paragraph 3390 of HC 395 (as amended)). Such circumstances will include being able to survive economically (see Januzi v Secretary of State for the Home department and Others  UKHL 5).
(3) There is no evidence that the Mungiki seek to impose FGM upon women or communities other than those who have been initiated into their particular sect. The sect generally is not found in areas occupied by those tribes whose ethnic groups (or sub-groups) are not Kikuyu or significantly so.
(4) This decision records updated evidence and provides new Country Guidance as to how issues of FGM and the Mungiki should be considered and approached in the light of such updated material.
"Having found the appellant to be credible, so far as her experiences in Kenya were concerned, the Adjudicator proceeded to dismiss her appeal, without having regard to material aspects of that account. In particular, the Adjudicator failed to consider the implications of the account, against the appellant's claim to be in fear (together with her daughter) of being compelled to undergo FGM in Kenya. The Adjudicator failed to have any regard to the background evidence relating to FGM in Kenya. In purporting to find that only one incident, namely the murder of the appellant's husband, had been reported to the authorities, the Adjudicator failed to take account at paragraph 7(A2) of the appellant's statement of 10 June 2003. In purporting to deal with internal relocation at paragraph 8 of the determination, the Adjudicator failed to have regard to the appellant's statement that she had tried to relocate to Nairobi but that the Mungiki had traced her to that city.
On 23 January, the respondent (represented by Mr Blundell) and the appellant (represented by Mr Bandegani) were in agreement that the matter should proceed to a second-stage reconsideration, at which the Tribunal would be required to determine, on the basis of current evidence, whether the appellant would be at real risk on return to Kenya of having to undergo (or being compelled to let her daughter undergo) FGM and/or other serious harm at the hands of the Mungiki sect. That risk would be assessed on the basis that, as effectively found by the Adjudicator, the appellant's account of her experiences in Kenya was credible."
Both P and M contended that there was a lack of state protection for women in Kenya at risk of violence and FGM and that such arose from the entrenched societal attitude towards Kenyan women generally.
The case of P was essentially that she had been ill-treated and beaten by her husband whilst living in Nairobi. It was the finding of the Adjudicator, as upheld by the court, that there was no effective protection available for her should she return to her home area. The issue of internal relocation had not been raised before the Immigration Adjudicator and it was considered inappropriate for that to be raised as an issue before the Court of Appeal. The case of M stemmed from the fact that her father had joined the Mungiki sect. He had inflicted FGM upon the appellant's sister and she fled to avoid the same fate. The Adjudicator had concluded that state protection for M would be neither adequate nor effective and that there was no reasonable possibility of internal relocation in her case. The Court of Appeal having regard to the case of Tsagaan v SSHD  EWCA Civ 1506 considered that the decision of the Adjudicator was 'plainly right' and should be restored. The Court recognised that there was a real danger of an overly technical approach being adopted to the application of the Refugee Convention.
50. In view of the reasoning set out above, we should make it clear that, particularly in view of Brooke LJ's reasons for giving leave to appeal, as we see it this case is more about the situations that may give rise to a claim for asylum or a right to a claim to protection under Article 3, than those situations that do give rise to such a claim. The decision does not mean that all women who are subject to cruelty and violence by their husband have an entitlement to asylum and protection under Article 3, only that P is so entitled. What is more, in her case, the issue of her ability to live safely in other parts of Kenya was never appropriately investigated, so it may be that if it had been, she would have not been entitled to asylum or the protection of Article 3.
51. In the case of M the position is similar. In her case her fear of FGM appears beyond doubt. If it is accepted that she could not be expected to avoid the risk of this being carried out against her will by residing in a different part of Kenya then her case, technicalities apart, was self evident. It is unfortunate indeed that the law has become so complicated that it has to be conceded that a very experienced IAT should have misdirected itself as to the law.
52. The real lesson of this case is the importance of appellate bodies not seeking to determine appeals to adjudicator's afresh."
We do not interpret the judgment in P & M as meaning that any woman in Kenya who can demonstrate a risk of having FGM performed upon her or being subjected to violence is entitled without more to be regarded as a refugee or fall within the protection afforded by the Qualification Directive. The court was concerned with cases which turned on their particular facts. Whether or not internal relocation is realistic or appropriate was seen as a matter which requires appropriate investigation.
(i) The Secretary of State will not make:
(a) a grant of asylum if in part of the country of origin a person would not have a well founded fear of being persecuted, and the person can reasonably be expected to stay in that part of the country; or
(b) a grant of humanitarian protection if in part of the country of return a person would not face a real risk of suffering serious harm, and the person can reasonably be expected to stay in that part of the country.
(ii) In examining whether a part of the country of origin or country of return meets the requirements in (i) the Secretary of State, when making his decision on whether to grant asylum or humanitarian protection, will have regard to the general circumstances prevailing in that part of the country and to the personal circumstances of the person.
(iii) (i) applies notwithstanding technical obstacles to return to the country of origin or country of return.
Such an issue raises three sub-issues, namely:-
(a) whether there exists a sufficiency of protection from the adverse attentions of the Mungiki;
(b) whether the relocation would itself expose the appellant to a real risk of FGM generally;
(c) whether relocation would be unreasonable or unduly harsh in all the circumstances.
The Appellant's Situation
"In paragraph 41, I noted that the Father told us about the Mungiki asking him about people he was believed to be sheltering. I believe that Mungiki suspected that we were with the father, because Mungiki in Nairobi must have seen my daughter and me in our nightdresses on the street and then going to the church. I believe that it was through this that word got back to the Mungiki who had attacked us as to where we were. The Father had been asked if he knew where a mother and daughter were, rather than having been asked for us by name."
The Expert Evidence
The General Objective Evidence
It reports that the Kenya Demographic and Health Survey (KDHS) revealed that:-
"Approximately 32 per cent of Kenyan women between the ages of 15 and 49 had been circumcised (Kenya July 2004, 251). From 1998 to 2003, the KDHS recorded a seven per cent decline in these cases (ibid., 250). However, the survey showed that the prevalence of FGM varied according to certain factors, such as age, education and ethnicity (ibid., 250-251).
According to the survey, 20 per cent of women between the ages of 15 and 19 had been circumcised, compared with 48 per cent of women between the ages of 45 and 49; 36 per cent of women who lived in rural areas had been circumcised, compared with 21 per cent in urban centres; approximately 50 per cent of Muslim women had been circumcised, compared with 33 per cent of non-Muslim women (ibid., 250). Moreover, the KDHS noted a strong negative correlation between FGM and a woman's level of education: 58 per cent of women with no education had been circumcised, while only 21 per cent of women who had graduated from high school had been circumcised (ibid.).
The following statistics show the percentage of women circumcised among the various ethnic groups.
|Embu (43.6)||Kalenjin (48.1)||Kamba (26.5)|
|Kikuyu (34.0)||Kisii (95.9)||Luhya (0.7)|
|Luo (0.7)||Maasai (93.4)||Meru (42.4)|
|Mijikenda/Swahili (5.8)||Somali (97.0)||Taita/Taveta (62.1)|
|Turkana (12.2)||Kuria (95.9)||Others (17.6) (ibid., 51)|
Note that Kisiis are also known as Abagusiis, Gisiis, Guziis, Kissiis.
The report went on to indicate that elders are responsible for making decisions regarding FGM, particularly determining the time and place for circumcision and the person who should perform it.
In 2001 the Ministry of Health circulated a policy directive making [FGM] illegal in all health facilities. In December 2003 the country signed the Masuto Protocol in which Article 5 stipulates that FGM should be prohibited and condemned. The government also implemented a National Plan of Action for the Elimination of FGM in Kenya. The plan aims to increase the number of communities supporting the elimination of FGM as well as the number of health facilities providing support services to victims.
Some sources are said to have noted that, in practice, the Children's Act is not being enforced or light sentences are being handed down. It is also said that Kenyan Parliamentarians have showed a reluctance to discuss FGM out of fear of losing votes.
A number of organisations and non-governmental organisations are specified in the report. Reference is also made to MYVO and its efforts to replace FGM with alternative rites of passage, which have been successful in various communities.
Particular Social Group
"For these reasons, I am satisfied that the appellant belongs to the group of uninitiated intact women who face persecution by enforced mutilation. If I am wrong in choosing that more limited group, then I would, of course, accept that the appellant falls within the larger social group of women and girls who face enforced mutilation."
The slightly wider definition is set out in paragraph 114 of the judgment, namely:-
"For these reasons, the particular social group might best be defined as Sierra Leonean women belonging to those ethnic groups where FGM is practised: then it is quite clear that the reason for the persecution is the membership of that group. But it matters not whether the group is stated more widely, as all Sierra Leonean women, or more narrowly, as intact Sierra Leonean Women from those ethnic groups. For all of them, the group has an existence independent of the persecution".
It was made clear in the course of the judgment in K & Fornah, particularly in paragraph 13 thereof, that to identify a social group one must first identify the society of which it forms part; a particular social group may be recognisable in one country but not in another.
A) Relocation – A Kikuyu Woman Remaining within Kirkuyu Culture and Territories
"Miss Sigley submitted there would be a sufficiency of protection for the appellant. She referred to the Secretary of State's bundle and the US State Department Report covering events in Kenya in 2003 and published on 25 February 2004. The law prohibited FGM for girls under eighteen and prohibited forced FGM on women of any age. The fact that 38% of women had undergone FGM demonstrated that a significant proportion had not. The practice was more widespread in some provinces than in others. A report from the German Development Corporation entitled 'Promotion of Initiatives to end FGM and Country Fact Sheet – Kenya GTZ' gave statistics for the prevalence rates among various ethnic groups. FGM prevalence rates in Kenya were declining in that material. The prevalence rate among the Kikuyu was 43%. The report showed that the Kenya Ministry of Health was coordinating activities in order to launch the national plan to abolish FGM. The government were working with NGOs and gave the project effective political and administrative support . 'By means of networking with local authorities it was possible to save girls from the threat of circumcision'. The achievements were listed on page 78 of the bundle – the prevalence rate of FGM in Koibatek district, for example, had declined to 2.2%. The report demonstrated the positive impact where the project had been undertaken. Societal attitudes had changed One of the most successful education programmes aimed at eradicating FGM in Kenya involved an alternative rite of passage in which girls were taken through all the formalities attending FGM but without undergoing the actual cut – see page 80 of the report prepared by the German Development Organisation. Some five thousand girls had participated. Those who had been circumcised were now condemning FGM in impressive numbers."
B) Relocation – Risk from Mungiki
"A small, controversial, cultural and political movement based in part on Kikuyu ethnic traditions, which espouses political views and cultural practices which are controversial in mainstream Kenya society. The number of Mungiki members is unknown, but the group draws a significant following from the unemployed and other marginalised segments of society."
"The Mungiki, a banned cultural and political movement and criminal protection racket based in part on Kikuyu traditions, was less organised and was implicated in fewer violent crimes than in the past due to a police crackdown. On February 10 and March 1 a total of thirty seven Mungiki members were released for lack of evidence in their murder charges. On May 9, the High Court acquitted for lack of evidence eleven Mungiki members who had been arrested in 2004 on various charges including the killings of a police officer and Mungiki defectors.
By the years end police arrested approximately twenty four suspected Mungiki members in connection with an upsurge in transportation sector crimes."
"There was a large internal security apparatus that included the Police Criminal Investigation Department (CID), the National Security Intelligence Service (NSIS), the National Police, the Administration Police and the Paramilitary General Services Unit. The CID investigates criminal activity, and the NSIS collects intelligence and monitors persons considered subversive. The security forces are under the authority of the Ministry of State for Provincial Administration and National Security in the Office of the President."
(C) Relocation – A Kikuyu Woman moving into a non-Kikuyu Area
"20. … It is, however, important, given the immense significance of the decisions they make, that decision-makers should have some guidance on the approach to reasonableness and undue harshness in this context. Valuable guidance is found in the UNHCR Guidelines on International Protection of 23 July 2003. In paragraph 7 II(a) the reasonableness analysis is approached by asking 'Can the claimant, in the context of the country concerned, lead a relatively normal life without facing undue hardship?' and the comment is made: 'If not, it would not be reasonable to expect the person to move there'. In development of this analysis the guidelines address respect for human rights in paragraph 28:
'Respect for human rights
Where respect for basic human rights standards, including in particular non-derogable rights, is clearly problematic, the proposed area cannot be considered a reasonable alternative. This does not mean that the deprivation of any civil, political or socio-economic human rights in the proposed area will disqualify it from being an internal flight or relocation alternative. Rather, it requires, from a practical perspective, an assessment of whether the rights that will not be respected or protected are fundamental to the individual, such that the deprivation of those rights would be sufficiently harmful to render the area an unreasonable alternative.'
They [UNHCR] then address economic survival in paragraphs 29-30:
The socio-economic conditions in the proposed area will be relevant in this part of the analysis. If the situation is such that the claimant will be unable to earn a living or to access accommodation, or where medical care cannot be provided or is clearly inadequate, the area may not be a reasonable alternative. It would be unreasonable, including from a human rights perspective, to expect a person to relocate to face economic destitution or existence below at least an adequate level of subsistence. At the other end of the spectrum, a simple lowering of simple standards or worsening of economic status may not be sufficient to reject a proposed area as unreasonable. Conditions in the area must be such that a relatively normal life can be led in the context of the country concerned. If, for instance, an individual would be without family links and unable to benefit from an informal social safety net, relocation may not be reasonable, unless the person would otherwise be able to sustain a relatively normal life at more than just a minimum subsistence level. If the person would be denied access to land, resources and protection in the proposed area because he or she does not belong to the dominant clan, tribe, ethnic, religious and/or cultural group, relocation there would not be reasonable. For example, in many parts of Africa, Asia and elsewhere, common ethnic, tribal, religious and/or cultural factors enable access to land, resources and protection. In such situations, it would not be reasonable to expect someone who does not belong to the dominant group, to take up residence there. A person should also not be required to relocate to areas, such as the slums in an urban area, where they would be required to live in conditions of severe hardship.'
These guidelines are, I think, helpful, concentrating attention as they do on the standards prevailing generally in the country of nationality. Helpful also is a passage of socio-economic factors in Storey, op cit, p 516 (footnotes omitted):
"Bearing in mind the frequency with which decision-makers suspect certain asylum seekers to be simply economic migrants, it is useful to examine the relevance to IFA claims of socio-economic factors. Again, terminology differs widely, but there seems to be broad agreement that if life for the individual claimant in an IFA would involve economic annihilation, utter destitution or existence below a bare subsistence level (Existenzminimum) or deny 'decent means of subsistence' that would be unreasonable. On the other end of the spectrum a simple lowering of living standards or worsening of economic status would not. What must be shown to be lacking is the real possibility to survive economically, given the particular circumstances of the individual concerned (language, knowledge, education, skills, previous stay or employment there, local ties, sex, civil status, age and life experience, family responsibilities, health, available or realisable assets, and so forth). Moreover, in the context of return, the possibility of avoidance of destitution by means of financial assistance from abroad, whether from relatives, friends or even governmental or non-governmental sources, cannot be excluded".
"First, it is essential when considering internal relocation to have regard to both considerations of: (1) safety, in the sense of an absence of persecution; and (2) reasonableness, in the sense of whether conditions are unduly harsh (Januzi, paragraphs 7, 8, 47 and 48).
Secondly, whilst it may be relevant to deciding a particular case to have regard to whether a person sought to avail himself of internal relocation prior to departure, the test of whether someone faces a real risk under the Refugee Convention and under Article 3 essentially concerns whether refoulement or return of a person would give rise to current risk: see for example Lord Bingham's approval at paragraph 20 of analyses made "in the context of return" and Lord Hope's reference in paragraph 48 to "the dangers of return".
Thirdly, there is no presumption that internal relocation is impossible simply because the persecutors in a person's home area are agents of the state. Nevertheless, evidence of state involvement, whether that involvement is direct or indirect, is relevant (paragraphs 21, 48 and 49).
Fourthly, the issue of reasonableness or whether conditions are unduly harsh is a rigorous one (Lord Carswell, paragraph 67); and it is wrong to decide this, is urged by Hathaway/New Zealand approach, by reference to whether those conditions meet the requirements of international human rights law in full. The issue is whether "conditions in that country generally as regards the most basic human rights that are universally recognised – the right to life and the right not to be subjected to cruel or inhuman treatment – are so bad that, it would be unduly harsh to expect a person to seek a place of relocation" (Lord Hope, paragraph 54). At most all that can be expected is that basic human rights standards, in particular non-derogable rights, are not breached.
Fifthly, it is of particular importance in the context of whether internal relocation is reasonable in the sense of unduly harsh that matters are looked at cumulatively, taking account of "all relevant circumstances": the importance of this approach is manifest from paragraphs 20-21 and 50 of their Lordships' opinions. "
(D) The Situation of the Appellant
"Clearly the appellant is in a 'social group' of a Mbari, or sub-clan, which is still devoted, or renewed in its devotion, to the custom of female genital cutting (FGC), long considered necessary by Kikuyu both for womanhood, morals, self respect and eligibility for marriage".
Such a comment does not, in our view, however address the practicalities that the appellant was married and has produced children but felt under no compulsion or requirement to undergo FGM. Little enquiry would seem to have been made of the appellant as to the community in which she resided or indeed to identify with any clarity any particular sub-clan of which she was a member. We find therefore such generalised comments to be without particular focus and unhelpful in our enquiries; and undermining of the weight which we can attribute to the report as a whole.
"In paragraph 41, I noted that the father told us about the Mungiki asking him about people he was believed to be sheltering. I believe that the Mungiki suspected that we were with the Father, because Mungiki in Nairobi must have seen my daughter and me in our nightdresses on the street and then going to the church. I believe that it was through this that word got back to the Mungiki who had attacked us as to where we were. The Father had been asked if he knew where a mother and daughter were rather than having been asked for us by name."
It is clear from the objective evidence that the Mungiki sect are very active in Nairobi particularly in the minibus and transportation business. The appellant and her daughter were dropped at the bus station in Nairobi and it is reasonable to expect that there would have been a Mungiki presence in or around that location. Such is far removed, however, from the suggestion that without such a sighting the Mungiki would have been able to or wished to have traced the appellant in Nairobi.
Wider Considerations of risk from FGM and Relocation Generally
a) The particular clan or sub clan of the claimant and whether in general such practices FGM and the degree to which it is practiced or enforced.
b) If so to consider the claimant's particular family, extended family and community. It is clear from the objective evidence that the degree to which FGM is practiced varies from clan to clan and from area to area within Kenya. It is also clear that within a particular clan area there may be a particular sub-clan or community which does not foster or encourage FGM. The objective evidence speaks of the influence of elders and church leaders to influence their respective communities. Thus the attitude of such influential community figures is an important factor to be borne in mind.
c) If a claimant does live within a community which practices FGM, the particular risk to her that it may be enforced must be considered. It will be necessary to consider in that context the ability of the family to protect her or the ability of the state authorities to offer protection. Given the nature of the objective evidence as has been placed before us it is unlikely that effective protection in such circumstances could be provided by state bodies.
d) In determining whether a claimant can be expected to relocate to another area or community within her clan or sub-clan's area it will be necessary to consider the family profile of the appellant including her education, her skills and family responsibilities. To such should be applied the principles as set out in Januzi, paragraphs 20-21, and in HGMO. It will be necessary for the decision maker to focus upon the issue of fundamental human rights, community support and economic survival to determine whether such a relocation would be unreasonable or unduly harsh in all the circumstances.
e) In determining whether a claimant can be expected to relocate to another area in Kenya, outside her own clan territory, similar considerations will need to be applied as in (d). It is to be borne in mind that the larger cities are by and large multi-ethnic and multi-cultural and there are clear areas in Kenya in which FGM is not practiced. Although it was suggested by Dr Knighton that it would be impossible for a woman of one clan to live in the territory or community of another clan, we could find no objective evidence to support such a bold assertion. There is little in the objective material drawn to our attention to indicate any significant hostility being exhibited as between the clans in Kenya. Clearly the claimant will be a new arrival and initial outsider in such regions. The issue of her ability to live and work in a given area will need to be addressed as an important factor. There is nothing to indicate significant hostility or inter-clan conflict in the cities, or in the region surrounding Lake Victoria occupied in the main by the Luo and Luhya.
(1) It is important to determine whether the claimant belongs to an ethnic group, amongst which group FGM is practiced. If so she may be a member of a particular social group for the purposes of the 1951 Geneva Convention.
(2) All uncircumcised women in Kenya, whether Kikuyu or not, are not as such at real risk of FGM. The statistical evidence shows that at least fifty per cent, if not more, of women in Kenya have not been the subject of FGM. The objective evidence shows an increasing pressure to abstain from such a practice both by many of the churches and communities, by the government and non-governmental agencies, by the promotion of an alternative "initiation rite".
(3) The decision to undergo FGM is one made by the individual if adult or by the parents if a child. Such a decision will no doubt be reflective of the cultural norms which exist within the particular community in which the woman or child resides. It is, however, possible for a woman not wishing to embrace the initiation of FGM for herself or her family to live in a community which does not subscribe to such practises. Those who practice FGM are not reasonably likely (particularly in urban areas) to seek to inflict it upon women from non-practising ethnic groups (or sub-groups).
(4) A woman will only be at real risk if she comes from an ethnic group (or sub- group) where FGM is practised and the evidence shows that she is reasonably likely to be required by her parents or by others, in a position of power and influence over her to undergo FGM.
(5) There is no evidence that the Mungiki seek to impose FGM upon women or communities other than those who have been initiated into their particular sect. The objective evidence speaks of the Mungiki as being involved in organised crime, transportation in urban areas and in public order offences. There is no evidence that they are engaged in any significant activity such as imposing FGM on groups or communities who do not support their political/cultural aims.
(6) The authorities are motivated to act against the Mungiki and in the past a significant number of arrests including the arrest of one of the leaders. The Mungiki seeks to reflect the traditional or cultural base of the Kikuyu. The sect generally is not found in areas occupied by those tribes whose ethnic groups (or sub-groups) which are not Kikuyu or which do not contain an element of the Kikuyu.
(7) Internal relocation will be available in Kenya to a woman who is at real risk of FGM in her home area if the evidence shows, (i) she is not reasonably likely to encounter anyone in the place of relocation who would be in a position of power and influence over her and who would use that power and influence to require her to undergo FGM; and (ii) she can reasonably be expected to live in that place, having regard to the general circumstance prevailing in it and the personal circumstances of the appellant (paragraph 3390 of HC 395 (as amended). In the case of a woman from a rural area in Kenya, internal relocation to some other region or urban centre will not be available unless her circumstances are such that she will be able to survive economically (see Januzi v Secretary of State for the Home Office and Others  UKHL 5).
(8) In considering internal relocation it is important to bear in mind the religious and/or cultural context particularly whether there is any family or sub-clan support available to the woman in the area proposed. It may be considered that it would be easier for a member of the Kikuyu tribe to relocate to an area with a similar tribal culture and support, rather than relocating into a different area. That having been said, however, much will depend upon the individual circumstances of the woman and of the availability of a support structure within the proposed area of return.
(9) Credibility will usually have an important part to play in determining whether a woman is at risk. In considering the issue of relocation it is important that the family and extended family situation and context be examined particularly as to cultural context, education, economic lifestyle and work experience.
Senior Immigration Judge King, TD
Map Of Kenya
BBC News Article (04/03/05)
UNHCR Guidelines and Position Papers (07/05/02)
Kenya Humanitarian Update (Jan 03)
IRIN News Article (07/02/03)
BBC News, Profile: Kenya's Secret Mungiki Sect (11/02/03)
Extract from Kenya Humanitarian Update (28/02/03)
US State Department Report on Kenya 2002 (31/03/03)
Extract from Kenya Humanitarian Update (30/04/03)
Newspaper Articles: East Africa Press (various dates)
Reply to RLC from UNHCR (02/07/03)
Report Centre for reproductive Rights of Kenya (2003)
Newspaper Articles and Responses to Information from Canada Refugee Board (Various dates)
'Ending Female Genital Mutilation' – Gemma Richardson 11/02/05.
Country of Origin Report 16 – February 2005 prepared by Immigration Refugee Board of Canada.
Responses to Information Request – 23 February 2005, Immigration and Refugee Board of Canada.
IRIN Report of FGM (March 2005)
US State Department Report on Kenya 2005 (08/03/06)
Letter from FCO Nairobi re Women and FGM (14/11/05)
Articles from Daily Nation (20/05/2006, 31/07/2006)
Operational Guidance Note – Kenya V1.0, (01/06/06)
WHO Article on FGM (02/06/06)
Article from East Africa Standard (20/06/2006)
Afro News Report on Kenya (26/06/06)
News Articles on FGM Kenya (various dates)
Expert Report Dr D P Knighton (25/07/06)
Various Articles from religionnewsblog.com (14/01/06, 02/02/06, 06/03/06, 09/05/06)
P& M v SSHD  EWCA Civ 1640
RM (Sufficiency of Protection – IFA – FGM) Kenya CG  UKIAT 00022
JA (Mungkiki – not a religion) Kenya  UKIAT 00266
JM (FGM – Sufficiency of Protection) Kenya  UKAIT 00050
AK (FGM – Sufficiency of Protection) Kenya  UKAIT 00080
Januzi (FC) v SSHD and Others  UKHL5
A and Fornah  UKHL 46.