BF v Secretary of State for the Home Department: blood feud asylum appeal allowed

The First-tier Tribunal (Immigration and Asylum Chamber) has allowed the asylum appeal of an Iraqi national, identified only as BF for anonymity purposes, after accepting his account of a blood feud arising from a fatal road traffic accident involving his father.

The decision, promulgated on 9 September 2026 following a hearing at Priory Courts, Birmingham, was handed down by Judge K Feeney. BF, born in October 2004, had appealed against the Secretary of State's refusal of his protection and human rights claims, a decision dated 20 August 2024 in respect of an application made in October 2022.

BF's claim centred on his fear of reprisals from the family of a man, referred to as G, who was killed in a car accident involving BF's father. He also raised a secondary ground relating to a lack of identity documentation, said to have been retained by the agent who facilitated his journey to the UK.

At the outset of the hearing, the parties narrowed the issues considerably. The Secretary of State accepted that the accident had occurred but did not concede that G's family held any adverse interest in BF, had threatened him, or possessed particular influence. Notably, the Presenting Officer declined to make submissions on whether the Refugee Convention was engaged, relying solely on the refusal letter's rejection of the point. Both parties agreed the appeal turned entirely on the credibility of BF's account, and that state protection and internal relocation would be unavailable to him only if his account of the family's influence were accepted.

Judge Feeney accepted Mr Sidhu's submission, unopposed by the Respondent, that potential victims of blood feuds constitute a particular social group, drawing on the Secretary of State's own Country Policy and Information Note on Iraq: Blood Feuds, Honour Crimes and Tribal Violence (July 2024) and applying the two-stage test set out in JCK (s.32 NABA 2022) Botswana [2024] UKUT 00100.

On the evidence, the judge found BF's account plausible, consistent and sufficiently detailed. She accepted that G's family had attended BF's family home accompanied by armed individuals, that threats had subsequently been made by telephone, and that the family held the degree of influence BF described. Apparent inconsistencies raised in the refusal letter were resolved on a fair reading of the witness statement and interview record, and the judge found BF's explanations for the two-week delay before leaving Iraq, his limited knowledge of G's family's precise standing, and his failure to claim asylum in France, all credible.

Having accepted BF's account of adverse interest and influence, and that the circumstances met the CPIN's definition of a blood feud, the judge concluded that state protection and internal relocation, including to the Iraqi Kurdistan Region, were not available to him. The appeal was allowed on asylum grounds; the humanitarian protection claim was dismissed as it fell away once refugee status was established. The existing anonymity direction was maintained, and no fee award was made given BF's fee remission.

The judgement offers a clear illustration of how tribunals are approaching blood feud claims as a recognised particular social group under the post-2022 statutory framework, and of the weight credibility findings continue to carry once the Secretary of State narrows the issues in dispute.