Singh v. Blanche

Court of Appeals for the Ninth Circuit·Decided May 21, 2026·No. 25-4096·Unpublished

Opinion

NOT FOR PUBLICATION FILED UNITED STATES COURT OF APPEALS MAY 21 2026 MOLLY C. DWYER, CLERK U.S. COURT OF APPEALS FOR THE NINTH CIRCUIT

NAVDEEP SINGH, No. 25-4096 Agency No. Petitioner, A215-674-445 v. MEMORANDUM* TODD BLANCHE, Acting Attorney General,

Respondent.

On Petition for Review of an Order of the Board of Immigration Appeals

Submitted May 18, 2026** Seattle, Washington

Before: TALLMAN, OWENS, and R. NELSON, Circuit Judges.

Navdeep Singh, a native and citizen of India, petitions for review of the

Board of Immigration Appeals’ (“BIA”) decision dismissing his appeal of an

Immigration Judge’s (“IJ”) decision denying his applications for asylum,

* This disposition is not appropriate for publication and is not precedent except as provided by Ninth Circuit Rule 36-3. ** The panel unanimously concludes this case is suitable for decision without oral argument. See Fed. R. App. P. 34(a)(2). withholding of removal, humanitarian asylum, and protection under the

Convention Against Torture (“CAT”). “Where, as here, the BIA cites [Matter of

Burbano, 20 I. & N. Dec. 872 (BIA 1994)] and also provides its own review of the

evidence and law, we review both the IJ’s and the BIA’s decisions.” Ruiz-

Colmenares v. Garland, 25 F.4th 742, 748 (9th Cir. 2022) (citation omitted). “We

‘review questions of law de novo’ and the agency’s ‘factual findings for substantial

evidence.’” Id. (citation omitted). As the parties are familiar with the facts, we do

not recount them here. We deny in part and grant in part the petition for review,

and remand for the agency to address the second prong of the humanitarian asylum

analysis in the first instance.

1. For asylum and withholding of removal, if an applicant demonstrates past

persecution, the Department of Homeland Security (“DHS”) bears the burden of

establishing by a preponderance of the evidence that the applicant does not have a

well-founded fear of future persecution because: (1) “[t]here has been a

fundamental change in circumstances”; or (2) “[t]he applicant could avoid future

persecution by relocating to another part of the applicant’s country . . . [and] it

would be reasonable to expect the applicant to do so.” 8 C.F.R.

§§ 1208.13(b)(1)(i)-(ii), 1208.16(b)(1)(i)-(ii).

The agency found that, although Singh established past persecution on

account of his political opinion, DHS had demonstrated that Singh could safely and

2 25-4096 reasonably relocate within India to avoid future persecution. Substantial evidence

supports the agency’s determination. The agency noted that: (1) Singh had been

accepted to the National Institute of Technology in Delhi and his admission had

never been cancelled; (2) Singh spoke English and Hindi fluently; (3) Singh did

not have any trouble during the three months he resided with his aunt in Delhi

before leaving for the United States; (4) Singh’s fears that the Bharantiya Janta

Party (“BJP”) would track him down outside of Haryana were not reasonable;

(5) Jats reside in many states throughout India; (6) seven out of ten chief ministers

in Haryana were Jats; (7) there was no evidence of generalized violence between

the Jats and non-Jats, or violence targeting political activists on either side, since

the February 2016 riots in Haryana; and (8) the BJP had accumulated significant

Jat support.

In addition, Singh argues that the BIA erroneously stated that the IJ did not

also rely on a “fundamental change in circumstances” to rebut the presumption of

future persecution. However, any error by the BIA was harmless because

relocation and changed circumstances are independent alternative grounds. See

Zamorano v. Garland, 2 F.4th 1213, 1228 (9th Cir. 2021).

2. Singh argues that the IJ violated his due process rights by allowing DHS

to admit Exhibit 10—a public news article that had not been previously filed with

the IJ—as rebuttal evidence during its cross-examination of Singh at the merits

3 25-4096 hearing.

To establish a due process violation, the petitioner must show: “(1) the

proceeding was so fundamentally unfair that the [petitioner] was prevented from

reasonably presenting his case, and (2) the [petitioner] demonstrates prejudice,

which means that the outcome of the proceeding may have been affected by the

alleged violation.” Zia v. Garland, 112 F.4th 1194, 1203 (9th Cir. 2024) (citation

omitted).

Singh fails to show that the admission of Exhibit 10 prevented him from

reasonably presenting his case. Singh’s counsel was given time to review Exhibit

10, offered no objection aside from timeliness, and did not ask Singh any questions

about Exhibit 10 on redirect. Cf. Cinapian v. Holder, 567 F.3d 1067, 1074-75 (9th

Cir. 2009) (finding a due process violation where the petitioners were not given a

pre-hearing opportunity to review forensic reports concluding that the petitioners’

documents were fraudulent and DHS did not make the reports’ author available for

cross-examination).

Moreover, Singh fails to show that he was prejudiced by the admission of

Exhibit 10. Although the IJ relied on Exhibit 10 for the proposition that the BJP

had been able to accumulate significant Jat support, the IJ also considered Singh’s

testimony and other evidence in the record to find that he could safely and

reasonably relocate to another part of India.

4 25-4096 3. “Regardless of whether the government has rebutted the presumption of

an asylum applicant’s well-founded fear of persecution, the BIA may still grant

humanitarian asylum.” Singh v. Whitaker, 914 F.3d 654, 661 (9th Cir. 2019). An

applicant seeking humanitarian asylum must show either (1) “compelling reasons

for being unwilling or unable to return” to his country of nationality “arising out of

the severity of the [applicant’s] past persecution,” or (2) “a reasonable possibility

that he or she may suffer other serious harm upon removal to that country.” 8

C.F.R. § 1208.13(b)(1)(iii).

The IJ set forth the above standard, but only addressed the first prong. The

BIA did not address humanitarian asylum, so it adopted the IJ’s decision under

Burbano. See Samayoa-Martinez v. Holder, 558 F.3d 897, 899 (9th Cir. 2009).

For the first prong, the record does not compel the conclusion that the

agency erred in finding that Singh’s past persecution did not rise to the necessary

level of atrociousness to warrant humanitarian asylum. See Singh, 914 F.3d at 662

(“Our case law demonstrates that extremely severe persecution is required to

warrant humanitarian relief.”).

The IJ did not address the second prong. The Government argues that Singh

failed to raise the second prong before the IJ or BIA, and therefore failed to

exhaust the issue. However, Singh explicitly raised the second prong in his pre-

hearing statement to the IJ, which is sufficient under Abebe v. Gonzales, 432 F.3d

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