M v Minister for Justice, Equality and Law Reform, Ireland and another (Case C-277/11); [2012] WLR (D) 359
“The co-operation requirement in the second sentence of article 4(1) of Council Directive 2004/83/EC of 29 April 2004 on minimum standards for the qualification and status of third country nationals or stateless persons as refugees or as persons who otherwise need international protection and the content of the protection granted, did not require a competent national authority to inform an applicant, whose application for refugee status had already been rejected, of its intention to refuse, and its reasons for refusing, a request for subsidiary protection before adopting such a decision in order to enable the applicant to make known his views in that regard.”
WLR Daily, 22nd December 2012
Source: www.iclr.co.uk