CAT/C/59/D/666/2015 complementary protection criterion was based on an assessment that contained only 6 paragraphs (out of a total of 184) addressing the protection issue. He further submits that the assessment was based on his status as having left the country illegally and on his links to LTTE, while there was no assessment of the risk he faces because of his association with Tamil nationalist politics and the Alliance. 5.3 In addition, in his application to the Federal Circuit Court, the complainant was not represented by counsel. Although the judge attempted to explain to him that the Court could only review legal errors, he did not understand that the Court did not have jurisdiction over findings of fact or the merits of his claims. 5.4 With regard to the evidence provided by the complainant, notably the letter from S.Y. and the photograph of the complainant with S.Y., he notes that no expert opinion was sought to determine the authenticity of the photograph or the letter. He objects to the reason given for doubting these two pieces of evidence — the fact that there is a high incidence of document fraud in Sri Lanka — and to the “amateur inspection of a printed image file”. He submits that while the Tribunal may be a specialized external review body, it is not specialized in identifying faked images and it is not totally external, as its members are appointed by the Government, their appointment process is not transparent and their independence is “not robustly verifiable”. 5.5 He further maintains, concerning his association with the Tamil National Alliance, that his involvement was because of close family connections to S.Y. and based on loyalty to the family’s “great man”, and that his knowledge of the politics involved was “very sparse” as he was only a loyal “foot soldier”. He adds that from his point of view, whether he was helping S.Y. or helping the Alliance may not have been very clear, but his association with S.Y. did continue beyond 2010 and even up to 2013 in Australia, for which he has provided new evidence before the Committee. 5.6 The complainant submits that his brother’s shooting taken in isolation is not key to his claim that he will suffer significant harm, but taken in the context of his long association with the Tamil National Alliance, in particular with S.Y., the possibility that he would be seen to have ongoing links to LTTE, both in Sri Lanka and in Australia, is heightened. 5.7 The complainant further refers to the suspicions that the Tamil National Alliance is a front for LTTE and engages in separatist politics, 8 and quotes witness statements contained in a report on an investigation into the alleged abduction and torture of 20 persons at the hands of “white van” people in 2015.9 State party’s additional observations 6. On 21 September 2016, the State party commented on the complainant’s submission dated 21 August 2016. It notes that that submission, including the country information referenced by the complainant’s counsel, contains no information that could change the assessment that the complainant’s claims do not engage the State party’s non-refoulement obligations under article 3 of the Convention. The State party further reiterates the content of its submission dated 10 December 2015. 8 9 6 The complainant provided the following link: https://tamiltigeractivities.wordpress.com/2016/03/19/tna-its-pathetic-proclamations-to-deceive-theun-and-srilanka/. The complainant referred to the International Truth and Justice Project Sri Lanka report entitled Silenced: Survivors of Torture and Sexual Violence in 2015 of January 2016, available from www.tamilnet.com/img/publish/2016/01/STOP_report_3_v5.1-2.pdf.