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            In the present case, the applicant is seeking "... to prevent the Minister from exercising a means of his removal from the State which will, if put into action, be much more difficult for him to resist " (para. 27 of the applicant's written legal submissions, dated 3 December 2024).
            As regards his exclusion from the State, the applicant submits that " ...the respondent has already decided the means she would use for that purpose is deportation" and " the Respondent has decided that the appropriate mechanism is deportation, not removal" (para. 19 of the applicant's written legal submissions).
            At the ex parte stage the applicant sought the following relief which is pleaded at para. (d) of their statement of grounds:
"(i)������ An order of certiorari quashing the Minister's decision to refuse to consider the applicant's application to be considered under the terms and provisions of the procedure established by the Respondents Department to deal with cases coming within the ambit of cases captured by the judgment of the CJEU in the case of Chenchooliah v. The Minister for Justice & Equality C - 94/18 - hereinafter referred to as the Chenchooliah judgment.
(ii)������� Further or in the alternative, an order of mandamus compelling the respondent to the (sic) consider the Applicant's case as one falling within the ambit of the Chenchooliah judgment.
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