Consultation Response to the Domestic Abuse Act statutory guidance

As frontline ‘by and for’ Black and minoritised and migrant organisations we welcome this second round of consultation of the draft domestic abuse statutory guidance. We recognise its importance in addressing the vulnerabilities that victims with insecure immigration status and those subjected to the No Recourse to Public Funds (NRPF) policy face accessing safety and support.

Nevertheless, we are concerned about the lack of understanding of how immigration laws add to this vulnerability. And the limited knowledge of how immigration status is a risk factor for women falling out of their status. We are worried about the guidance endorsement of the NPCC guidance on information sharing of victims suspected to be immigration offenders overlooking the current review the Home Office is undertaking in this area.

Our response primarily focuses on “Chapter 2, Understanding Domestic Abuse”, as it covers the intersectional considerations of the experiences of domestic abuse women from marginalised groups encounter. However, we consider that this intersectional lens should be extended and addressed throughout the whole guidance as in its current state fails to do.

As frontline organisations supporting migrant women, we often encounter difficulties when advocating for the safety of victims with precarious legal status. In many cases, frontline professionals in statutory services argue not having any obligation to support them as they do not have access to public funds or regular status. We recommend the guidance calls on statutory services providers to effectively treat victims as victims first and foremost and ensure that services are provided to them without discrimination.

This submission is endorsed by the Latin American Women’s Rights Service (LAWRS), Southall Black Sisters (SBS), Middle Eastern Women and Society Organisation (MEWSo), Kurdish and Middle Eastern Women’s Organisation (KMEWO), the East European Resource Centre (EERC), Safety4Sisters North West, Latin American Women’s Aid (LAWA), IKWRO – Women’s Rights Organisation, Al Hasaniya MWC, the Angelou Centre and Asian Women’s Resource Centre.

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