Dear Minister

Re: XXX

I act for XXX, an Iranian national currently held in ZZZ detention centre.

I understand from recent news reports that you have reached agreement with the government of Iran to repatriate Iranian nationals to Iran against their will.

XXX is a person who, owing to well-founded fear of being persecuted for reasons of race, religion, nationality, membership of a particular social group or political opinion, is unwilling to return to Iran. If he is returned there, his/her life or freedom will be threatened on account of his/her race, religion, nationality, membership of a particular social group or political opinion.

[modify previous para to accord with circumstances]

If you return XXX to Iran, it will amount to refoulement contrary to Australia’s obligations under the Convention Relating to the Status of Refugees 1951 and the 1967 Protocol.

Please give your written undertaking within 3 business days that you will not return XXX to Iran. Unless I receive that undertaking, I will seek injunctive relief withour further notice.