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In page R (Secretary of State for the Home Department) v Immigration Appeal Tribunal and Surinder Singh:

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This case established a precedent for British citizens to secure UK immigration rights for their non-European spouses, who are unable to join their partners because of several changes in UK immigration law aimed at reducing net migration. Through EU Regulations on Free Movement of Peoples, it provides a window of opportunity to reunite UK citizens with their spouses in the increasing number of cases where the new rules on income and other additional measures mean that such spouses of UK citizens would otherwise be separated by the requirements of increasingly strict visa controls.[citation needed]