T: 020 313 76185 Level 30, The Leadenhall

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E: info@lawlex.co.uk Street, London EC3V 4AB

Our Ref: 02023-Kakabadze

HO Ref: AIC/7126297
Your Ref:1212-0099-0016-8498
Date: 03.10.2023
South East Asylum Team
4th Floor
Lunar House
40 Wellesley Road
Croydon
CR9 2BY

By email: Virtualasylumteamadmininbox@homeoffice.gov.uk /
AOMGeneralEnquiries@homeoffice.gov.uk /
ROMLunarHouseGeneralEnquiries@homeoffice.gov.uk/
ngcinterviews@homeoffice.gov.uk

Dear Sir or Madam

Re: Asylum representations
Lead Applicant Mrs Tsiuri Kakabadze 12 April 1983 Georgia
Linked Applicant ( Mr Giorgi Chogovadze 06 September 1982 Georgia
formerly)
Son ( Separate Mr Gegi Chogovadze 25 May 2002 Georgia
Application) Ref: AIC/7705333 / case
ID: 31958625
British Child Luka Kakabadze 26 June 2023 British

INTRODUCTION

1. We write on behalf of our client, Ms Tsiuri Kakabadze (hereafter, ‘our client’), in

regard to her asylum claim, for which she had a substantive interview last week.

2. Ms Kakabadze is a national of Georgia who has lodged an asylum claim in the UK.

As detailed extensively below, she has strong grounds for asylum based on her

political opinion and activities in Georgia with the United National Movement party.

She was an active supporter of UNM and faced threats, physical assault, and

politically motivated prosecution due to her work in Georgia.

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3. In addition to her well-founded fear of persecution if returned to Georgia, Ms

Kakabadze also has compelling grounds to remain in the UK as the primary caregiver

and sole guardian of her British child. Removing Ms Kakabadze from the UK could

undermine her child's rights and welfare as a British citizen.

4. It is noted that despite repeated requests, we have not been provided with a copy of

Ms Kakabadze's substantive asylum interview transcript. As such, this representation

has been written without the benefit of seeing the interview notes in full. Once the

transcript is disclosed, we reserve the right to make additional representations

informed by its contents.

FACTUAL BACKGROUND

5. Ms Kakabadze was an active supporter of the United National Movement party in

Georgia and faced threats, physical assault, and politically motivated prosecution due

to her political activities. This is corroborated by the testimony of Ms Tamila

Gigashvili, Ms Kakabadze's colleague who was also targeted and has been granted

asylum in the USA.

6. Ms Kakabadze has provided a statement during her asylum interview regarding her

political activities in Georgia, the targeting and threats she faced, and her well-

founded fear of persecution if returned.

7. Specifically, as an active member and supporter of the United National Movement

party, Ms Kakabadze participated in peaceful rallies, campaigns, and outreach to

promote human rights, democracy, and fair elections in Georgia.

8. Due to her visible affiliation with UNM, Ms Kakabadze was repeatedly threatened,

surveilled, publicly vilified, and physically assaulted by supporters of the ruling

Georgian Dream party and affiliates of the government.

LawLex Solicitors LTD is a company registered in England and Wales with registration number 12502721. Registered office at The Leadenhall
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9. The threats and attacks against Ms Kakabadze escalated during the course of her

UNM activities. She received death threats directed at her and her family. These

threats were credible given the political climate and her public affiliation with UNM.

10. This targeting corroborates the evidence of Ms Tamila Gigashvili, Ms Kakabadze's

colleague who fled Georgia after facing similar persecution due to her UNM activism.

Ms Gigashvili has been granted asylum in the USA, confirming the risk faced by

UNM supporters such as my client.

11. She has been subjected to threats from the family of her deceased friend and her

family members were weaponised against her. Her activities and the deceased

family’s tragedy are entwined and have the same foundation.

12. Moreover, while in the UK, Ms Kakabadze has become the mother and guardian of a

British child. Forcibly removing her from the UK could deprive her child of their

rights and stability as a British citizen. This would undermine the child's welfare and

be severely contrary to their best interests during formative years.

LEGAL SUBMISSIONS

13. Based on her political activities with UNM, Ms Kakabadze has a well-founded fear of

persecution if returned to Georgia. The specifics of her work, the timing and

escalation of threats, her public affiliation with UNM, and the evidence of her

similarly situated colleague Ms Gigashvili all corroborate this fear.

14. Ms Kakabadze's asylum claim is further supported by Country Guidance case law,

background materials, and precedent decisions involving UNM members facing

political persecution in Georgia.

15. Additionally, removing Ms Kakabadze from the UK would violate Article 8 of the

ECHR given her role as the primary guardian and caregiver of a British child.

LawLex Solicitors LTD is a company registered in England and Wales with registration number 12502721. Registered office at The Leadenhall
Building 122 Leadenhall St, Lime Street, London EC3V 4AB. We are authorised and regulated by the Solicitors Regulation Authority: 806029.
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Forcibly separating Ms Kakabadze from her child could deprive the child of their

British nationality rights and stability. This separation would clearly run contrary to

the child's welfare and best interests.

16. Ms Kakabadze has been resident in the UK for an extended period awaiting the

outcome of her asylum claim. During this time she has established her family life here

by giving birth to and caring for her British child. Abruptly disrupting this

longstanding family life would impose undue hardship on both Ms Kakabadze and her

child.

17. The prolonged processing of the asylum claim also places increasing hardship on Ms

Kakabadze as the provider and caregiver for her infant. Delaying a granting of asylum

prolongs the precarious situation of Ms Kakabadze's young family. A swift, positive

resolution is critically needed for their stability and welfare.

18. In consideration of all of the above, it is overwhelmingly in the best interests of the

child - as well as Ms Kakabadze's right to asylum - for Ms Kakabadze to be granted

leave to remain in the UK. Removing her would be disproportionate and severely

detrimental to her child's welfare and family life.

19. Furthermore, it is submitted that forcibly removing Ms Kakabadze from the UK

would severely exacerbate existing health issues. The prolonged uncertainty and

instability of her immigration status has already had a significant negative impact on

her mental health and wellbeing. Forcibly uprooting her would worsen her

psychological state and pose grave risks to her physical health and safety as well. The

Home Office is urged to factor in these compassionate health grounds when

adjudicating her case.

CONCLUSION

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20. In light of the above, it is submitted that Ms Kakabadze has strong grounds for asylum

and family life in the UK. Removing her would be disproportionate and counter to the

best interests of her British child.

21. I submit she cannot safely return to Georgia due to her well-founded fear of

persecution. Moreover, as primary caregiver to a British child, it would be

unconscionable to remove Ms Kakabadze and undermine her child's welfare and

family life.

22. I trust these representations clearly set out the compelling grounds for Ms Kakabadze

to remain in the UK. Please contact me if you require any further information. I look

forward to a positive resolution upholding her right to asylum and family life.

Kind Regards
Lawlex Solicitors
Ruslan Ughrelidze
Solicitor Advocate
Higher Rights of Audience (Civil)

Enc:
• Witness account of Tamila Gigashvili, Grant of status, Her identification documents
as available at present
• Documents form witnesses of facts from Georgia
• Evidence of Property ownership and Relocations due to persecution
• Evidence of Health from the UK and Georgia
• Evidence of Political activities, letters, images etc
• Evidence of family relationships, birth certificates etc
• Photographs of Incidents
• Sentencing remarks and Pardon Decree for Alleged crime
• Evidence of Friend death and ensuing events
• Evidence of report crime in Georgia
• Evidence of Court proceedings
• Evidence of Employment, ownership of business
• Diploma

LawLex Solicitors LTD is a company registered in England and Wales with registration number 12502721. Registered office at The Leadenhall
Building 122 Leadenhall St, Lime Street, London EC3V 4AB. We are authorised and regulated by the Solicitors Regulation Authority: 806029.
Information Commissioner Registration Number is ZA797376. List of directors can be inspected at Company Registered address upon request.
 T: 020 313 76185 Level 30, The Leadenhall
F: 020 347 54149 Building, 122 Leadenhall
E: info@lawlex.co.uk Street, London EC3V 4AB

• Letter from Schools confirming children have been relocating frequently

• Evidence of Relocations at various addresses
• Other collaborative evidence

LawLex Solicitors LTD is a company registered in England and Wales with registration number 12502721. Registered office at The Leadenhall
Building 122 Leadenhall St, Lime Street, London EC3V 4AB. We are authorised and regulated by the Solicitors Regulation Authority: 806029.
Information Commissioner Registration Number is ZA797376. List of directors can be inspected at Company Registered address upon request.