Thank you for the additional information.
At an appeal hearing, what the court considers is a review of the documents that would have been before the Home Office at the time they made they made the decision refusing your mother leave to remain and whether based on that evidence they find that the Home Officer would have made an error in law. This means the tribunal will consider whether the Home Office:
- did not apply the correct law or wrongly interpreted the law
- did not follow the correct procedures
- had no evidence or not enough evidence to support its decision
Now, i am not sure when you applied to extend on what basis you applied for her to do so, as, her entitlement to this is not of right. If the application were to be granted, it would have had to rest on a UK citizen's right to private/family life and not necessarily because of all the things you have mentioned are wrong with your mother. You perhaps need to focus primarily on the the third test above and ask on the basis of that for the Tribunal to allow you to submit evidence to demonstrate how her being asked to return home will affect the UK citizens.
I must say that this will be a difficult case particularly as the rules generally do not permit persons to switch from a visistors visa to any other category in country. Furthermore, there is a visa category which allows someone like your mother to apply for from Zimbabwe specifically to allow her to enter the UK to be taken care of by her family. Please see below visa:
It is likely therefore that even if they find her situation to be debilitating ot so serious in nature that would require her to cared for by relatives, the Home Office may still pose the question as to why she did not apply for the above permit from Zimbabwe. I would encourage you therefore to be prepared to address the Tribunal on this.
i do hope I was able to put things into perspective for you.
All the best RL