Singh v. Holder, 2011 U.S. App. LEXIS 8973

Singh is an Indian citizen who lived in Canada for ~2.5 years after an unsuccessful Canadian asylum claim and entered the United States without inspection.
He applied for U.S. asylum, swore to truth, but later admitted his application and supporting documents were false.
He alleged Sikh political persecution and family arrests/beatings in India, claims later retracted.
The IJ denied asylum; the BIA affirmed without opinion; Singh seeks review.
Singh produced fraudulent documents and perjured testimony at asylum interviews and merits hearings.
The IJ considered curative testimony and potential corroboration from Singh’s father, who was present but not cross-examined due to confidentiality and lack of waiver issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility based on past lies and lack of corroboration	Singh contends internal consistency should prove credibility	IJ properly questioned credibility due to fraud and absence of corroboration	Supported by substantial evidence; past fraud and lack of corroboration justify disbelief.
Continuance to secure father’s corroboration	Singh deserved continuance to obtain father’s testimony	No entitlement to second continuance; prior four weeks adequate	IJ did not abuse discretion in denying second continuance.

Gulla v. Gonzales, 498 F.3d 911 (9th Cir. 2007) (fraud in leaving country not dispositive; asylum merits address credibility separately)
Akinmade v. INS, 196 F.3d 951 (9th Cir. 1999) (use of documents to enter U.S. can be consistent with claim to persecution)
Zi Lin Chen v. Ashcroft, 362 F.3d 611 (9th Cir. 2004) (availability of corroboration affects credibility assessment)
Kaur v. Ashcroft, 388 F.3d 734 (9th Cir. 2004) (otherwise credible testimony may require corroboration when not readily available)