New country guidance case on Kurds returned to Iraq

AAH (Iraqi Kurds – internal relocation) (CG) [[2018] UKUT 212 (IAC)](http://www.bailii.org/uk/cases/UKUT/IAC/2018/212.html) is a recent country guidance case on the availability of internal relocation for Iraqi Kurds to the Iraqi Kurdish Region.

This case updates some of the guidance contained in AA (Iraq) v SSHD [[2017] EWCA Civ 944](http://www.bailii.org/ew/cases/EWCA/Civ/2017/944.html), which had in turn corrected the previous Iraqi country guidance case in the Upper Tribunal of AA (Iraq) v SSHD [[2015] UKUT 544 (IAC)](http://www.bailii.org/uk/cases/UKUT/IAC/2015/544.html).

In particular, it considers whether or not internal relocation by an Iraqi Kurd to the IKR would be reasonable given the obstacles he or she would face: namely, getting there from Baghdad, crossing the border into the IKR, and then living there.

The case re-emphasises the importance of obtaining an Iraqi Civil Status Identity Document (“CSID”) for all returnees, the possession of which will impact heavily on the feasibility of relocation.

Further analysis available in our article at Free Movement

Main image credit: Photo by Levi Meir Clancy on Unsplash