HE (Bidoon – statelessness – risk of persecution) Kuwait CG [2006] UKAIT 00051

The prior controlling Country Guidance case, now superseded in its specific documentary test by NM (2013) but still the citable authority for the general historical trajectory of Bidoon risk assessment. Heard at Birmingham 22 March 2006 (Asylum and Immigration Tribunal); promulgated 21 June 2006. HELD: no material change in Bidoon risk since the earlier 2004 guidance in BA and Others — stateless Bidoon remained at real risk of persecution and of a breach of their Article 3 ECHR rights. USE IN A REPORT: cite for the historical continuity of the risk finding (2004→2006→2013), and note explicitly that NM (2013) changed the DOCUMENT test (security card, not 'civil identification documents') without disturbing HE's underlying risk conclusion for undocumented Bidoon — conflating the two is a common drafting error worth pre-empting in submissions.

Now of primarily historical value; best cited alongside NM (2013), not in place of it.