Humanitarian and Compassionate Applications: A Critical Look at Canadian Decision-Makers’ Assessment of Claims from “Vulnerable” Applicants
2. Processing and Assessment of Humanitarian and Compassionate Considerations and Impacts on Rejected Applicants
3. Ensuring That the Best Interests of the Child Prevail in Any Assessment of H&C Applications
25. (1) Subject to subsection (1.2), the Minister must […] examine the circumstances concerning the foreign national and may grant the foreign national permanent resident status or an exemption from any applicable criteria or obligations of this Act if the Minister is of the opinion that it is justified by humanitarian and compassionate considerations relating to the foreign national, taking into account the best interests of a child directly affected.[…]
(1.21) Paragraph (1.2)(c) does not apply in respect of a foreign national
- (a) who, in the case of removal, would be subjected to a risk to their life, caused by the inability of each of their countries of nationality or, if they do not have a country of nationality, their country of former habitual residence, to provide adequate health or medical care; or
- (b) whose removal would have an adverse effect on the best interests of a child directly affected.
 […] Therefore, attentiveness and sensitivity to the importance of the rights of children, to their best interests, and to the hardship that may be caused to them by a negative decision is essential for an H&C decision to be made in a reasonable manner. While deference should be given to immigration officers on s. 114(2) [now s. 25 of the IRPA] judicial review applications, decisions cannot stand when the manner in which the decision was made and the approach taken are in conflict with humanitarian and compassionate values.
 The “best interests of the child” are determined by considering the benefit to the child of the parent’s non-removal from Canada as well as the hardship the child would suffer either from her parent’s removal from Canada or her own voluntary departure should she wish to accompany her parent abroad. Such benefits and hardship are two sides of the same coin, the coin being the best interest of the child.
 It is true that the best interests of the child cannot be assessed in a vacuum […] in the context of an H&C application [and] must be assessed in a reasonable manner. Where the interests of children are minimized, in a manner inconsistent with Canada’s humanitarian and compassionate tradition and the Minister’s guidelines, the decision will be unreasonable. The applicable Minister’s guidelines in this instance […] provide that a child’s emotional, social, cultural and physical welfare should be taken into account.
 I find that there is a defect in the process by which the Officer’s conclusions were drawn in respect to the best interests of the child and as a result, the interests of the child were minimized. Consequently, the Officer failed to accord sensitive consideration to the best interests of the child. I am satisfied that this constitutes an unreasonable exercise of discretion and warrants the Court’s intervention.28
The codification of the principle of “best interests of a child” into the legislation does not mean that the interests of the child outweigh all other factors in a case. While factors affecting children should be given substantial weight, the best interest of a child is only one of many important factors that the decision maker needs to consider when making an H&C decision that directly affects a child. [emphasis in original]
 [T]he words “shall be construed and applied in a manner that complies with” are mandatory and appear to direct courts to give the international human rights instruments in question more than persuasive or contextual significance in the interpretation of the IRPA. By providing that the IRPA “is to be” interpreted and applied in a manner that complies with the prescribed instruments, paragraph 3(3)(f), if interpreted literally, makes them determinative of the meaning of the IRPA, in the absence of a clear legislative intent to the contrary.
4. A Worrying Trend: An Increase in Refusal Rates Paralleling an Increase in the Number of H&C Applications
Current practices needlessly subject applicants and their families to the emotional and financial hardship of impending separation […]. Removal steps, deferral requests and stay applications also put an unnecessary strain on the limited resources of the [government] and Federal Court […]. And while people who are removed from Canada before their Stage 1 decision are theoretically allowed to return once it has been granted, there is no guarantee that their return will be authorized. Evidence shows that those who have been removed from Canada are far less likely to get a favourable Stage 1 decision in the first place.(CBA 2019)
Institutional Review Board Statement
Informed Consent Statement
Data Availability Statement
Conflicts of Interest
Legislation and JurisprudenceA.B. v. Bragg Communications Inc., 2012 SCC 46.Bailey v. Canada (Citizenship and Immigration), 2014 FC 315.Baker v. Canada (Minister of Citizenship and Immigration),  2 S.C.R. 817.Begum v. Canada (Citizenship and Immigration), 2013 FC 824.Canada (Minister of Citizenship and Immigration) v. Vavilov, 2019 SCC 65.Convention on the Rights of the Child, Can. T.S. 1992 No. 3, art. 3(1).De Guzman v. Canada (Minister of Citizenship and Immigration), 2004 FC 1276.Hawthorne v. Canada (Minister of Citizenship and Immigration), 2002 FCA 475.Hebberd v. Canada (Citizenship and Immigration), 2022 FC 27.Herman v. Canada (Citizenship and Immigration), 2010 FC 629.Immigration and Refugee Protection Act, S.C. 2001, c. 27, ss. 3(3)(f), 12, 25, 25.1, 25.2, 28, 34, 35, 36, 37, 38(1), 39, 42, 49(2), 60, 65, 67(1)(c), 68(1), 69(2), 72(1), 96-97. 112, 115(1).Immigration and Refugee Protection Regulations, SOR/2002-227, ss. 207(d), 215(g) 230, 232, 233.Kanthasamy v. Canada (Citizenship and Immigration), 2015 SCC 61.Kaur v. Canada (Public Safety and Emergency Preparedness), 2019 FC 1581.Kisana v. Canada (Minister of Citizenship and Immigration), 2009 FCA 189.Legault v. Canada (Minister of Citizenship and Immigration), 2002 FCA 125.Michel v. Graydon, 2020 SCC 24.M.M. v. United States of America, 2015 SCC 62.Mohammed v. Canada (Citizenship and Immigration), 2022 FC 1.Nwaeme v. Canada (Citizenship and Immigration), 2017 FC 705.Okoye v. Canada (Citizenship and Immigration), 2018 FC 1059.Owusu v. Canada (Minister of Citizenship and Immigration), 2004 FCA 38.Protecting Canada’s Immigration System Act, S.C. 2012, c. 17.Ramprashad-Joseph v. Canada (Minister of Citizenship and Immigration), 2004 FC 1715.Singh v. Canada (Citizenship and Immigration), 2014 FC 621.Somera Duque v. Canada (Citizenship and Immigration), 2007 FC 1367.Thamotharem v. Canada (Minister of Citizenship and Immigration), 2007 FCA 198.
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- United Nations. 2013. General comment No. 14 (2013) on the Right of the Child to Have His or Her Best Interests Taken as a Primary Consideration (art. 3, para. 1). Available online: https://www2.ohchr.org/english/bodies/crc/docs/gc/crc_c_gc_14_eng.pdf (accessed on 28 January 2022).
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Despite the challenges resulting from the COVID-19 pandemic, Canada admitted over 184,500 new permanent residents in 2020. In December 2021, Canada announced it had reached its target and welcomed more than 401,000 new permanent residents in 2021. This is the highest number of newcomers in a year in Canadian history (Canada 2021a).
The Canadian portion of the project is funded by the Canadian Research Council (grant agreement no. 2001-2019-0003) and the Fonds de recherche du Québec—Société et Culture (grant agreement no. 294442) as part of an international research initiative (the VULNER project) which has received funding from the European Union‘s Horizon 2020 research and innovation program (grant agreement no. 870845). The VULNER project includes researchers from Europe (Belgium, Germany, Italy and Norway), the Middle East (Lebanon), Africa (Uganda and South Africa) and Canada.
During the first phase of the project (April–December 2020), the Canadian team examined over 377 legal and policy documents in their first report, including legislation and regulations, guidelines, manuals, and ministerial instructions produced by government departments. Our study was complemented by an analysis of over 884 cases of the Supreme Court, Federal Court (Trial Division and the Appeal Division), Provincial Courts, and the Immigration and Refugee Board of Canada (IRB). Over 100 secondary sources, among them documents issued by UN agencies, NGOs and lawyers as well as academic publications were also analyzed. The second phase of the project (currently underway) includes interviews with migrants, “on-the-ground” practitioners (mainly lawyers and NGO workers), civil servants from Immigration, Refugees and Citizenship Canada (IRCC) as well as board members from the IRB.
In the spring of 2021, we signed a “Research Partnership Arrangement” with Immigration, Refugees and Citizenship Canada. This agreement stipulates that IRCC will circulate information to its employees concerning the research project, together with an introduction letter to participants from the research team inviting them to participate to a 60 min interview with us and a list of topics/themes covered during the interview. The agreement also indicates that IRCC will provide the research team with names of IRCC officials interested in and available for an interview with the team. Finally, it specifies that participants interviewed for the project will be offered the option to remain anonymous. In each interview selected for this paper, the immigration officer wished to remain anonymous. To fully ensure their anonymity, we do not specify in this paper when the interview took place. We only refer to immigration officers as “Immigration Officer A”, “Immigration Officer B” etc. (note that participants are NOT presented in the order they were interviewed).
Section 25(1) of the IRPA reads as follows:
Sections 25 (request of a foreign national for H&C considerations) and 25.1 (Minister’s own initiative for H&C considerations) of the IRPA should not be confused with s. 25.2 of the IRPA (public policy considerations). Section 25.2 deals with public policies implemented by the Minister to grant permanent resident status to groups of people who share common characteristics (see, e.g., the temporary public policy for out-of-status construction workers in the Greater Toronto Area (IRCC 2021h)). Such public policies generally have strict criteria, and individuals who do not meet the criteria cannot access the collective measure. Our article does not deal with s. 25.2 of the IRPA: it is only focused on the humanitarian and compassionate program under s. 25, which operates on a case-by-case basis.
In an interview with us, Immigration Officer R noted that, in exceptional cases, officers may however proceed to an examination of H&C considerations coming from inadmissible applicants under ss. 34, 35 and 37 of the IRPA if they “think that humanitarian and compassionate considerations really need to be looked at, such as, first instance, if the best interests of a child are at stake or if the person is at risk in their own country of origin”. It should also be noted that foreign nationals found inadmissible on criminality (s. 36 of the IRPA), medical (s. 38(1)) or financial (s. 39) grounds, or whose family members are found inadmissible (s. 42), may submit an H&C request to overcome their inadmissibility.
Pursuant to s. 25(1.01) of the IRPA, a “Designated Foreign National” is subject to a five-year ban on H&C applications. “Designated Foreign Nationals” are members of a group of people who arrive in Canada together and are called “irregular arrivals” by the Minister of Public Safety and Emergency Preparedness. This ban may be invoked, for example, if the Minister suspects that they have been brought to Canada through human smuggling or trafficking with the help of a criminal organization or terrorist group. The implications of being a “Designated Foreign National” are significant. For example, all “Designated Foreign Nationals” over the age of 16 face mandatory detention for a minimum of two weeks, and if they cannot establish their identity within two weeks, they will be detained for an additional six months, with the potential for another six months after that, with no judicial review of their detention. Further, designated claimants who are denied refugee status have no access to the Refugee Appeal Division. For more on this topic, see: (Neylon 2015; Atak et al. 2018; Labman and Liew 2019).
Interestingly, the Federal Court recently noted in Hebberd (2022) that officers should not rely on an alternative immigration stream that is not feasible or realistic to refuse an H&C application:
Under current provisions of the IRPA, individuals from countries affected by moratoria on removal (TSRs) may make a refugee claim (s. 96 or s. 97), apply for permanent residence through the in-Canada spousal category (s. 12) or apply on H&C grounds (s. 25), but it is not uncommon that the latter is the only option available for applicants. For example, when the TSR affecting Burundi, Rwanda and Liberia was lifted in 2009, a policy was adopted to grant an administrative deferral of removals (ADR) to nationals of these countries while their applications for permanent residence on H&C grounds were being assessed (IRCC 2013). The same policy was adopted when the TSR affecting Haiti and Zimbabwe was lifted in 2014 (IRCC 2016d). As of January 1st, 2022, there was a TSR in place for 3 countries (Afghanistan, the Democratic Republic of Congo and Iraq), and there was an ADR in place for 11 countries (certain regions in Somalia, the Gaza Strip, Syria, Mali, the Central African Republic, South Sudan, Libya, Yemen, Burundi, Venezuela and Haiti). However, as highlighted by the Canadian Council for Refugees (CCR), “[i]n mid-2021, a pattern has emerged of refusals of applications for [H&C] consideration from nationals of moratoria countries”. The CCR notes that these refusals are “particularly concerning” because, despite these negative H&C decisions, nationals of moratoria countries continue to live in Canada for several years with a very uncertain status. For more on this specific topic, see: (CBSA 2020; CBSA 2021; CCR 2021). For more on refusals of H&C applications generally, see Part 4 of this paper (below).
For more on this subject, including historical context and critical H&C reform propositions, see Davis and Waldman 1994.
Program Delivery Instructions used by IRCC staff provide more details on relevant factors that may be raised by applicants. They state that a request for H&C consideration may be based “on any relevant factors including, but not limited to: establishment in Canada for in-Canada applications; ties to Canada; the best interests of any children directly affected by the H&C decision; factors in their country of origin including adverse country conditions; health considerations including inability of a country to provide medical treatment; family violence considerations; consequences of the separation of relatives; inability to leave Canada has lead to establishment (in the case of applicants in Canada); ability to establish in Canada for overseas applications; any unique or exceptional circumstances that might merit relief” (IRCC 2016c).
The Stage 1 assessment, however, must not duplicate the refugee determination process set out in ss. 96 and 97 of the IRPA. Section 25(1.3) specifies that the role of IRCC officers making a decision on an H&C application is not to determine if a person is at risk of persecution, although it does not preclude them from considering evidence of hardship affecting the applicant.
The standard of proof when reviewing the evidence is the balance of probabilities (IRCC 2017b). This standard of proof poses the following question: is the information presented likely to be true?
It should be noted, however, that there are a few examples in the case law where the vulnerability of applicants has been explicitly underlined by the Federal Court. See specifically Nwaeme 2017 (elderly woman with mental health and mental capacity problems); Ramprashad-Joseph 2004 (elderly); Bailey 2014 (poor and disabled); Begum 2013 (impoverished woman); Okoye 2018 (bisexual man with three children).
For example, Immigration Officer R noted: “It’s a personal feeling [but for me] the most vulnerable people are children, women, and the elderly […], these are the people that need the most help”. Immigration Officer S told us that a vulnerable applicant is “probably somebody who does not understand the proceedings […] what’s happening and what is the case to be met or what needs to be presented”. This officer also referred to individuals without status and who are in a situation that puts them “at risk” (such as abuse at work) as “particularly vulnerable”. For Immigration Officer T, vulnerability is a broad concept which “may include” unaccompanied minors or pregnant women, but also “a person who has experienced trauma, who fears authorities in their country of origin”. For Immigration Officer U, children are particularly vulnerable applicants: “Children that are cancer patients, for example. And they’re facing removal with their parents to country X. These are the ones that stand out. Or children with special needs who get a lot of support here and they’re potentially facing removal. And they might be Canadian born but they’d be going back with the parents who are foreign nationals […]”. For Immigration Officer V, it is “basically anyone looking for a better life outside of their countries of origin, for themselves, for their children, for their future family. They’re vulnerable. They’re leaving their homes. They’re going somewhere different. They have mostly no English skills, so they come, and they don’t know how to speak to even a representative that could help them apply for refugee status, or any other stream of immigration that could legalize their stay in Canada”. At the same time, this interviewee indicated that “the most vulnerable” are “the children who come with them” and “women who experience sexual violence, such as female genital mutilation” in their countries.
For more on this topic, see: (Kaga et al. 2021).
A $550 processing fee must be included with the H&C application, and a $500 right of permanent residence fee must be paid if the H&C is successful. Additional fees are also required if the application includes a spouse and/or one (or several) dependent child(ren) (IRCC 2021c). Those fees are disproportionately affecting vulnerable applicants.
As noted by the Supreme Court of Canada in Vavilov (2019), “concerns regarding arbitrariness will generally be more acute in cases where the consequences of the decision for the affected party are particularly severe or harsh” (par. 134).
Applicants receiving a refusal on their permanent residence application under humanitarian and compassionate grounds may file an Application for Leave and for Judicial Review of the refusal at the Federal Court of Canada if they believe that the decision is unreasonable (i.e., that there is an error in the decision-making process). However, the deadline to file a leave application is very short (15 days from the date that the refusal letter was received) and the Federal Court process can take many months. It is also worth noting here that the Federal Court process comprises of two steps: first, the leave application (permission to go to court) and second, the judicial review hearing. It is only if applicants get permission (which is rarely granted) that they can argue their case within a hearing at the Federal Court. If the hearing is successful, then the H&C application is generally sent back to the IRCC office for a redetermination based on the Federal Court decision. A successful judicial review cannot be conducted without the assistance of an experienced lawyer who can carefully determine if it is worth contesting the decision and who ensures that the file is processed correctly.
See also Thamotharem (2007, para. 55), wherein the Federal Court of Appeal noted that “[e]ffective decision making by administrative agencies often involves striking a balance […] between the benefits of certainty and consistency on the one hand, and of flexibility and fact specific solutions on the other”.
See also: Thamotharem 2007, FCA, paras. 62–72; Herman 2010, FC, para. 28.
This is a good practice among administrative institutions, as they “routinely rely on standards, policy directives and internal legal opinions to encourage greater uniformity and guide the work of frontline decision makers” (Vavilov 2019, para. 130).
In 2006, the Immigration and Refugee Board issued the “Chairperson Guideline 8: Procedures with Respect to Vulnerable Persons Appearing Before the IRB”, amended in 2012 (IRB 2012). The Guideline on Vulnerable Persons defines vulnerable persons in the context of procedures before the IRB as “individuals whose ability to present their cases before the IRB is severely impaired”. It includes a non-exhaustive list of persons who may be vulnerable: “Such persons may include, but would not be limited to, the mentally ill, minors, the elderly, victims of torture, survivors of genocide and crimes against humanity, women who have suffered gender-related persecution, and individuals who have been victims of persecution based on sexual orientation and gender identity”. IRB guidelines are not mandatory but “provide guiding principles for adjudicating and managing cases” (IRB 2022). In fact, “decision-makers are expected to apply them or provide a reasoned justification for not doing so” (ibid).
In Vavilov (2019, para. 130), the Supreme Court pushed for the use of a wide variety of resources by administrative bodies: “Of course, consistency can also be encouraged through less formal methods, such as the development of training materials, checklists and templates for the purpose of streamlining and strengthening institutional best practices, provided that these methods do not operate to fetter decision making”.
Article 3(1) of the Convention on the Rights of the Child provides that “[i]n all actions concerning children, whether undertaken by public or private social welfare institutions, courts of law, administrative authorities or legislative bodies, the best interests of the child shall be a primary consideration”.
The IRPA makes specific reference to the “best interests of the child” in the following provisions: s. 25(1) and (1.21)(b) (H&C considerations—request of a foreign national); s. 25.1(1) (H&C considerations—Minister’s own initiative); s. 28(2)(c) (residency obligation of permanent residents); s. 60 (detention of minor children); s. 67(1)(c) (appeal before the Immigration Appeal division); s. 68(1) (stay of a removal order); s. 69(2) (Minister’s appeal before the Immigration Appeal Division respecting a permanent resident or a protected person).
In addition to the above cases, which set out the main principles surrounding the best interests of the child in H&C applications, Canadian courts have also ruled that immigration officers must examine the best interests of all children concerned—not just Canadian-born children or children who are the applicants, but also children living overseas (for example, a child outside Canada who is being supported by a parent who is in Canada). However, the onus is on the applicant to raise the issue clearly and provide the necessary evidence. Courts have also ruled that it is unreasonable and insufficient for an immigration officer to not consider the best interests of the child by simply stating that it is up to the parent to decide whether to take the child with him/her, if the parent is removed. For more on this topic, see: (Corrigan and Mejia 2020, p. 6); Owusu 2004, FCA, paras. 5–10.
The IRCC Guidelines (IRCC 2016b) start by highlighting that an H&C decision “must include an assessment of the best interests of any child directly affected by the decision”, which means in this context “a Canadian or foreign-born child (and could include children outside Canada)”. They continue by stating that “the relationship between the applicant and ‘any child directly affected’ need not necessarily be that of parent and child, but could be another relationship that is affected by the decision” (a grandparent as the primary caregiver for instance), and that it must be “sufficiently clear from the material submitted that an application relies in whole, or at least in part, on [the best interests of the child] factor”. The guidelines also note that, “in assessing H&C submissions, the decision makers must be ‘alert, alive and sensitive’ to the best interests of the children” (referring to Baker) and should “bear in mind that ‘[c]hildren will rarely, if ever, be deserving of any hardship” (referring to Hawthorne). They emphasize that the outcome of an H&C decision that directly affects a child “will always depend on the facts of the case” and that “circumstances which may not warrant humanitarian and compassionate relief when applied to an adult may nonetheless entitle a child to relief”, since “children may experience greater hardship than adults faced with a comparable situation” (referring to Kanthasamy). IRCC Program Delivery Instructions also state that “factors relating to a child’s emotional, social, cultural and physical welfare should be taken into account when raised. Some examples of factors that applicants may raise include but are not limited to: the age of the child; the level of dependency between the child and the H&C applicant; the degree of the child’s establishment in Canada; the child’s links to the country in relation to which the H&C assessment is being considered; the conditions of that country and the potential impact on the child; medical issues or special needs the child may have; the impact to the child’s education; matters related to the child’s gender” (IRCC 2016b).
These data were initially obtained by Jenny Kwan (immigration affairs critic of the New Democratic Party) through an access to information request (Toronto Star 2021).
Immigration lawyers, such as Steven Meurrens (2016), had already predicted this issue a few years ago:
For example, Immigration Officer R highlighted that the workload of immigration officers is now approximately 35 cases per trimester, instead of 8 to 10 cases per month a few years ago. This same officer also explained that there have been changes in the calculation method: if an application includes six people—for example, two parents and four children—it is now only compiled as one case rather than six. According to this officer, the targets are not reasonable because they do not sufficiently consider the complexity of some applications. Immigration Officer S and Immigration Officer U also told us that the targets set are not “completely logical” and that it’s “quite a lot of work” for immigration officers, but both noted that immigration officers can always go to their manager and explain their situation.
Even if the right to be heard is “[o]ne of the fundamental components of natural justice”, this right does not encompass the right to an interview in the H&C context, as it is primarily a paper-based process (IRCC 2014a). When credibility issues are central in a case, officers are nonetheless invited to set up an interview with the applicant, as a poor credibility assessment could be under scrutiny in the event of a request for judicial review at the Federal Court (IRCC 2014b). Of note, IRCC Program Delivery Instructions encourage immigration officers to use “less contentious” phrases when recording their reasons, especially if no interview was completed (IRCC 2014g). For example, it is stated that phrases such as “I am not satisfied” should be used rather than “I do not believe”, as the latter suggests that credibility is being questioned and that it has been “fully investigated”.
It is worth noting that this policy applies to all applicants, including failed refugee claimants. A conditional removal order is issued to rejected refugee claimants in Canada. It comes into force 15 days after the refugee claim has been rejected (s. 49(2) of the IRPA).
Under s. 112(1) of the IRPA, individuals in Canada may apply for a PRRA if they are subject to a removal order that is in force. The PRRA assessment is completed by IRCC immigration officers who must determine, pursuant to s. 115(1) of the IRPA, whether a person would be at risk of persecution or at risk of torture, or of any other cruel and unusual treatment or punishment, if they would be removed to their country of origin. A PRRA involves a formal risk assessment that does not use the same criteria as the H&C assessment, although it is not uncommon that people submit both PRRA and H&C applications simultaneously (IRCC 2014e). As we explained in Part 2, the H&C assessment “is not limited to the PRRA’s specific legislative parameters of persecution”. A person may not apply for a PRRA if less than 12 months have passed since the date of the last negative decision of the IRB on their refugee determination or of the last negative decision of the Federal Court concerning their application for leave or judicial review of the IRB decision, or since a previous PRRA application (s. 112(2) of the IRPA), unless a specific country has been exempted from the 12 month bar requirement (s. 112(2.1)). As soon as a PRRA application is filed, the removal order is stayed for the duration of the process (s. 232 of the IRPR). For more on this subject, see: (Kaga et al. 2021; IRCC 2020b).
The IRPA makes specific reference to the “humanitarian and compassionate considerations” in the following provisions: s. 25(1) (H&C considerations—request of a foreign national); s. 25.1(1) (H&C considerations—Minister’s own initiative); s. 28(2)(c) (residency obligation of permanent residents); s. 65 (criteria to prevent H&C factor before the IAD when an application is based on membership in the family class); s. 67(1)(c) (appeal before the IAD); s. 68(1) (stay of a removal order); s. 69(2) (Minister’s appeal before the IAD respecting a permanent resident or a protected person). Our article deals solely with the H&C program under s. 25 of the IRPA. The other provisions only provide H&C relief in the specific contexts mentioned herein (i.e., appeals before the IAD). For more on this subject, see: (Canada 2020; IRB 2008; IRB 2009).
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Delisle, A.; Nakache, D. Humanitarian and Compassionate Applications: A Critical Look at Canadian Decision-Makers’ Assessment of Claims from “Vulnerable” Applicants. Laws 2022, 11, 40. https://doi.org/10.3390/laws11030040
Delisle A, Nakache D. Humanitarian and Compassionate Applications: A Critical Look at Canadian Decision-Makers’ Assessment of Claims from “Vulnerable” Applicants. Laws. 2022; 11(3):40. https://doi.org/10.3390/laws11030040Chicago/Turabian Style
Delisle, Anthony, and Delphine Nakache. 2022. "Humanitarian and Compassionate Applications: A Critical Look at Canadian Decision-Makers’ Assessment of Claims from “Vulnerable” Applicants" Laws 11, no. 3: 40. https://doi.org/10.3390/laws11030040