The Court of Appeal is clearly at pains to ensure that both tiers of the Tribunal get the law right when considering appeals in relation to foreign national criminals. As acknowledged in the recent case of The Secretary of State for the Home Department v AJ (Zimbabwe) [2016] EWCA Civ 1012, “There has been a plethora of cases which have come to this court concerning the application of article 8 to foreign criminals and in particular seeking to clarify the scope of the residual “exceptional circumstances” concept. The principles of law are well established and not in dispute in these appeals and therefore I will do no more than summarise the effect of the leading authorities”.