Persecution in the Fog of War: The House of Lords\u27 Decision in \u3cem\u3eAdan\u3c/em\u3e

In this Article, we argue that the House of Lords\u27 reasoning in Adan was seriously flawed. The House of Lords correctly recognized that evidence that minorities face a heightened risk of being persecuted can be sufficient to show a nexus to a Convention ground. Yet it erred when it went on to hold that only differentially at-risk individuals or groups can benefit from refugee status. If a person\u27s risk of being persecuted is causally linked to his or her race, religion, nationality, membership of a particular social group, or political opinion, the nexus requirement is satisfied irrespective of whether the applicant is a member of a minority group that is particularly vulnerable to harm