The “Internal Flight Alternative” (IFA) Test and the Concept of Protection

The “internal flight alternative” or “IFA” is an integral part of the definition of refugee as contained in Article 1A(2) of the 1951 Convention on the Status of Refugees. Recognition of its status as such has been an established feature of the international jurisprudence on the IFA. ¹ In the United Kingdom case law, however, it has had a chequered history. Indeed it is fair to say that it was only in the very recent full judgment of the Court of Appeal in the case of ex parte Robinson, ² that we now have a leading case which ranks alongside earlier flagship cases commonly identified in the international jurisprudence on asylum law.