A party must be able to challenge a flawed decision. The submission may identify missing investigations, incomplete reasoning, an incorrect assessment of evidence or a disproportionate duration of the entry ban. These statements remain connected to the decision and its effects.
The risk of an order penalty increases when the submission targets individuals with degrading language and the substantive issue disappears. The challenged passage should be read together with the full paragraph. A pointed assessment may be understood differently when it explains a concrete error than when it is a personal attack without a connection to the case.
A clear structure helps in practice: state the finding in the decision, identify the legal objection, refer to the evidence and then set out the requested step. This makes it clear which wording serves the legal defence and which wording adds no further legal point.