On 12 April 2017, the Home Office’s Section 94 Certification Policy Guidance was updated in order to, “provide further clarification of when to certify a human rights claim and to reflect the need to give reasoning when certifying a claim as set out in FR & KL (2016) v SSHD EWC CIV”.(Certification of protection and human rights claims under section 94 of the Nationality, Immigration and Asylum Act 2002 (clearly unfounded claims).