The Nigerian applicant claimed a fear of female genital mutilation (FGM). The Tribunal found that she could have internally relocated within Nigeria. The applicant challenged this decision on the basis that she had not been given an opportunity to address the Tribunal on the matter of internal relocation and that the Tribunal had not considered internal relocation with regard to her particular circumstances.
In refusing leave, the Court held that the question of internal relocation is inextricably linked to the question of refugee status and that the applicant should have anticipated that the matter would arise.