A summary of the Irish Human Rights Commission's position on the Immigration Bill.
• The scope of ministerial discretion and the manner of its exercise must be defined with sufficient clarity to provide people with protection against arbitrary interference.
• Provisions to protect victims of trafficking should include all victims and not just foreign nationals.
• Current provisions on protection for victims of trafficking should be significantly extended to reflect internationally agreed minimum standards.
• Serious consideration should be given for an independent appeals mechanism of all immigration decisions.
• Individuals should not be removed from the State while there is an application for a judicial review of a decision to deport him/her.
• Detention of asylum applicants is "to be avoided" and should be used only as a measure of last resort. That principle should be stated in law.
• Prisons and Garda stations are not suitable places for the detention of protection applicants who have not been convicted of a criminal offence,
• Decisions of the Protection Review Tribunal, which would replace the Refugee Appeals Tribunal, should be published,