“Women in the Ivory Coast” can constitute a PSG under the Refugee Convention because they share a general position of inferiority in Ivorian society compared to men (paras. 282–284). It will depend on each applicant's “own particular circumstances, including her cultural, social, tribal, or regional background” (para. 4), to determine whether she faces persecution because she belongs to that particular social group.

The risk of harm that women in the Ivory Coast face as a result of “FGM, forced marriage, domestic violence, and the effects of adultery and discrimination” (para. 279) is serious enough to amount to persecution and inhumane treatment in breach of their rights under Article 3 of the ECHR. Due to a strong contrast in attitudes towards women, this risk is significantly higher in traditional rural communities than in urban areas. An adult female who faces one or more of those risks is unlikely to access sufficient protection, but internal relocation to an urban centre may be possible without causing undue hardship.

In light of the Country Guidance (CG) findings, the Upper Tribunal dismissed MD’s appeal on “asylum, humanitarian protection and human rights grounds” under Articles 3 and 8 of the ECHR (para. 329). Although the appellant was at risk of suffering isolation and stigmatization that would render her life intolerable in the northern village of Odienne, she and her son could return safely to Abidjan, a cosmopolitan and multi-ethnic urban centre. Although their removal would constitute an interference with the appellant’s private life in the UK, such interference would be proportionate to the public interest in maintaining an effective immigration control.