views this as needless ambiguity. since the Senate Judiciary Committee Report. we note approvingly. goes to considerable lengths to interpret "habeas corpus under the Constitution" broadly. The Report states that custody includes those "parole pending their hearing" as well as physical custody for purposes of habeas corpus. The Report interprets "under the Constitution" to include not only whether the individual adjudication was "through fundamentally fair procedures" but whether the procedures could be "relied on for an objective determination. on the merits. of whether or not the individual applicant satisfies the statutory definition of refugee in INA section 101(a)(42)". thus implying review encompassing statutory and treaty obligations. The Senate Report also makes it clear that individual or multiparty habeas actions are allowed. .5