Judgments

Decision Information

Decision Content

IMM-1-91
Joseph Smith and Sarah Smith (Applicants)
v.
Her Majesty the Queen (Respondent)
INDEXED AS: SMITH V. CANADA (T.D.)
Trial Division, Cullen J.—Toronto, February 5 and 12; Ottawa, March 11 1991.
Immigration — Refugee status — Applicants, Iraqi citizens, entering Canada on forged documents, with weapons price list and literature published by militant Shiite Islamic organiza tion opposed to Iraqi regime detained as possible security risks — Certificate issued under s. 40.1 stating not qualifying for admission as suspected members of inadmissible classes — Court quashing certificate as unreasonable — When personal liberty at stake, high degree of probability required — Cred ible explanation for weapons list — Admitted involvement with organization — Absent more evidence as to individual proclivity or involvement of applicants in terrorism, further detention unreasonable.
Immigration — Practice — Minister issuing certificate under s. 40.1 of Act stating applicants not qualifying for admission to Canada as suspected members of inadmissible classes — Order extending time to serve applicants with notice of proceedings, allowing respondent to advance evidence of CSIS officer, permitting hearing to be conducted in camera and security intelligence reports be sealed — Compliance with notice provision in s. 40.1(3)(b) not pre-condition to review by Court under s. 40.1(4), although departures from statutory standard condoned only where substantial compliance with three-day time limit, and lack of prejudice to named person's interests — Within Court's jurisdiction to extend time ex parte — As s. 40.1(4)(a) gives judge discretion to hear evidence ex parte if disclosure injurious to national security, by implica tion may make orders necessarily incidental to exercise of discretion — S. 40.1(4)(a) expressly allowing Court to hear oral evidence in camera for national security reasons and by implication decide to hear such evidence in camera — S. 40.1 (4)(b) not requiring judge to prepare summary himself Certificate referred to Court as soon as reasonably possible in circumstances, thus complying with `forthwith" ins. 40.1(3)(a) — Under s. 40.1(4) judge sitting on review having discretion to determine whether any part of information should not be disclosed on grounds disclosure injurious to national security or safety of persons — Guidelines in Henrie v. Canada (Secu-
rity Intelligence Review Committee) applied — Disclosure of sealed file material injurious to national security.
These were proceedings under Immigration Act, section 40.1 to review a certificate issued thereunder to determine if it was reasonable. The applicants, Iraqi citizens, had entered Canada on January 9, 1991 on forged documents and claimed Conven tion refugee status. They had in their possession a price list for weapons and ammunition and literature published by the Al -Dawa party, a militant Shiite Islamic organization which is opposed to the current Iraqi government, and which engaged in terrorist operations against Iraq with the support of the Iranian government. CSIS believed that Al -Dawa had been involved in bomb attacks against the French and American embassies in Kuwait. Mr. Smith (applicants herein referred to by pseudo nyms Joseph and Sarah Smith by Court order) admitted his association with Al -Dawa. He had been jailed for two years in Iraq for suspected membership in Al -Dawa. After his release he fled to Iran and fought against Iraq in 1984. Through Al -Dawa he provided basic religious instruction to Kurds in 1985. He returned to Iran where he met and married his wife. When Iraq invaded Kuwait, Iraqi exiles in Iran were to be forcibly repatriated to Iraq. Smith decided to flee to Canada as he feared for his life should he be returned to Iraq. He stated that the weapons price list had been compiled in 1986 when he was at the Al -Dawa base in Iraq. A Kurdish arms merchant had quoted the prices of his inventory should Al -Dawa be interested in purchasing such goods.
The Smiths were detained as possible security risks. The Minister of Employment and Immigration and the Solicitor General filed a certificate under Immigration Act, section 40.1 stating that the applicants did not qualify for admission to Canada because they were suspected of being members of inadmissible classes. The effect of the certificate was to provide for the continued detention of the applicants and to prevent any further inquiry into their refugee status until the certificate has been reviewed in the Federal Court to determine whether it was reasonable.
Upon examination of the security intelligence reports con sidered by the Minister and the Solicitor General and hearing evidence presented by a CSIS officer, Cullen J. granted an order extending the time to serve the applicants with notice of the proceedings under paragraph 40.1(3)(b) from three days to four after the certificate had been filed. The order also provided that the respondents be allowed to advance the evidence of the CSIS officer, that the hearing be conducted in camera in the absence of the applicants and that the security intelligence reports be sealed and kept separate from public court files.
The applicants objected that: (1) the Court lacked jurisdic tion to extend the time for service, and that compliance with the notice requirements of subsection 40.1(3) was a condition precedent to the Court's review function; (2) the Court lacked jurisdiction to make such orders on an ex parte basis; (3) s. 40.1 only authorizes in camera examination of the security reports, so that the decision of the Court to hear the additional evidence of the CSIS officer in camera should not have been made in camera; (4) the summary of the information provided to the applicants did not comply with paragraph 40.1(4)(b) as the judge had not drafted it personally; (5) the reference of the certificate to the Federal Court had not been filed "forthwith" as required by paragraph 40.1(3)(a); (6) the Court should order that fuller disclosure be provided to the applicants.
Held, the certificate should be quashed.
As to the preliminary objections: (1) Compliance with the notice provision in paragraph 40.1(3)(b) is not a pre-condition to the exercise of the Court's review function under subsection 40.1(4). That Parliament did not intend strict observance of the notice provisions as a pre-condition to the Court's jurisdiction is supported by the fact that the statute contemplates that in some circumstances, a review may be conducted before the person named in the certificate need be notified of the fact that a certificate has been filed. "Shall" in subsection 40.1(3) is directory, not mandatory. While statutory provisions should be observed where possible, it may not always be practical where national security is at risk to require strict compliance where there is no serious prejudice to the person named. In addition, no specific consequence is provided for the failure to provide notice. As the person named in the certificate does not partici pate until after the in camera review, the failure to notify the applicants within the prescribed three-day period has not seri ously prejudiced them. As the purpose of this notice provision is to ensure that the person is aware of the reasons for detention and the possibility of deportation, departures from the statutory standard should only be condoned where there has been sub stantial compliance with the three-day provision and a lack of prejudice to the named person's interests. The delay in provid ing notice was one day, which is neither significant nor unduly prejudicial.
(2) Paragraph 40.1(4)(a) gives the Court discretion to hear evidence in the absence of the person named in the certificate if disclosure of same would be injurious to national security or the safety of persons. This right extends by implication to the making of orders necessarily incidental to the exercise of this discretion and therefore the judge need not hear submissions on these orders.
(3) Paragraph 40.1(4)(a) expressly authorizes a judge to "hear any other evidence or information" in camera in his discretion for national security reasons. By implication the decision to hear oral evidence in camera may also be made in camera.
(4) There is no express requirement in paragraph 40.1(4)(b) that the summary be prepared by the judge himself. The judge's function is to ensure that the person named has been reasonably informed.
(5) "Forthwith" has been held to mean "as soon as possible in the circumstances". The certificate was referred to the Court as soon as was reasonably possible in the circumstances. When the liberty of an individual is at stake, the matter should be brought before the Court with all reasonable speed. The respondent had to gather the necessary evidence and informa tion to be presented in Court. Such research necessarily took time after the certificate was issued. Since part of the time was over a weekend, the time was reasonable in the circumstances.
(6) Subsection 40.1(4) gives the judge sitting on review of the certificate the discretion to determine whether any part of the information or evidence should not be disclosed on the grounds that the disclosure would be injurious to national security or the safety of persons. The disclosure of the sealed file material would be injurious to national security. Applying the guidelines set out in Henrie v. Canada (Security Intelli gence Review Committee), it would be inappropriate to com ment on the reasons for sealing the documents, as the com ments could identify the evidence. The same would apply to the request to produce the persons requested for cross-examination.
The certificate was not reasonable. Where personal liberty is at stake, the standard of proof of reasonableness is a high degree of probability. There was not sufficient evidence for the Minister to have concluded that the applicants were members of the inadmissible classes. Although there was evidence as to the suspected activities of Al -Dawa, there was no evidence as to the potential for subversive activities by the applicants as individuals. Nor was it reasonable to consider that the appli cants would engage in acts of violence that would endanger people in Canada or that they belonged to an organization likely to engage in such activities. Without more evidence as to the individual proclivity or involvement of the applicants in terrorism or other violence, further detention was not reasonable.
STATUTES AND REGULATIONS JUDICIALLY CONSIDERED
Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.) [R.S.C., 1985, Appendix II, No. 44], s. 7.
Federal Court Rules, C.R.C., c. 663.
Immigration Act, R.S.C., 1985, c. I-2, ss. 2, 12, 19(1)(f),(g), 40, 40.1 (as enacted by R.S.C., 1985 (4th Supp.), c. 29, s. 4), 103(3)(b) (as am. by R.S.C., 1985 (4th Supp.), c. 28, s. 27), 103.1 (as enacted idem, s. 12).
CASES JUDICIALLY CONSIDERED
APPLIED:
R. v. Parrot (1979), 27 O.R. (2d) 333; 106 D.L.R. (3d) 296; 51 C.C.C. (2d) 539 (C.A.); Henrie v. Canada (Security Intelligence Review Committee), [1989] 2 F.C. 229; (1988), 53 D.L.R. (4th) 568 (T.D.); Reg. v. Secre tary of State for the Home Department, Ex parte Khawaja, [1984] A.C. 74 (H.L.).
DISTINGUISHED:
Neal v. A.G. (Sask.) et al., [1977] 2 S.C.R. 624; (1977), 56 C.C.C. (2d) 128; 17 N.R. 67; R. v. Garofoli, [1990] 2 S.C.R. 1421; (1990), 80 C.R. (3d) 317.
CONSIDERED:
Secretary of State for Education and Science v. Tame- side Metropolitan Borough Council, [1977] A.C. 1014 (H.L.).
AUTHORS CITED
Jones, David Phillip and de Villars, Anne S. Principles of Administrative Law, Toronto: Carswell Co. Ltd., 1985.
COUNSEL:
Clayton Ruby and Gregory James for applicants.
Winston K. H. Fogarty, Josée Desjardins and Mylène Bouzigon for respondent.
SOLICITORS:
Ruby & Edwardh, Toronto, for applicants.
Deputy Attorney General of Canada for respondent.
The following are the reasons for order ren dered in English by
CULLEN J.: The applicants in this matter applied to be admitted to Canada as refugees. They were detained as possible security risks, and then brought before an adjudicator who reviewed the circumstances of their detention. The adjudica tor ruled that continued detention was not war ranted and ordered that they were to be released on conditions. The Minister of Employment and Immigration and the Solicitor General then issued a certificate pursuant to section 41 of the Immi gration Act, 1976 (S.C. 1976-77, c. 52, as enacted by S.C. 1988, c. 36, s. 4, now s. 40 of the Immi-
gration Act, R.S.C., 1985, c. I-2, as enacted by R.S.C., 1985 (4th Supp.), c. 29, s. 4) (hereinafter "the Act"). The certificate states that the appli cants, in the opinion of the Ministers, do not qualify for admission to Canada because they are members of classes of persons described in para graphs 19(1)(f) and 19(1)(g) of the Act, which read as follows:
19. (1) No person shall be granted admission who is a member of any of the following classes:
(/) persons who there are reasonable grounds to believe will, while in Canada, engage in or instigate the subversion by force of any government;
(g) persons who there are reasonable grounds to believe will engage in acts of violence that would or might endanger the lives or safety of persons in Canada or are members of or are likely to participate in the unlawful activities of an organiza tion that is likely to engage in such acts of violence;
The effect of such a certificate is to provide for the continued detention of the applicants notwith standing the order of the adjudicator, and to pre vent any further inquiry into their refugee status until the certificate has been reviewed in the Fed eral Court. Pursuant to paragraph 40.1(3)(a) of the Act, the ministerial certificate has been referred to the Federal Court of Canada for review by myself as a judge designated by the Chief Justice of this Court to determine whether the certificate is reasonable on the basis of the evi dence and information available to me.
BACKGROUND
I propose to review the facts of this matter in considerable detail before moving on to the legal issues. The applicants, Iraqi citizens who are hus band and wife, entered Canada on January 9, 1991 at Pearson International Airport in Toronto on a flight from Tokyo. Upon arrival they sought entry to Canada as Convention refugees, and were examined by an immigration officer under section 12 of the Act. The applicants stated that they had left Iran on January 1, 1991 for Kuala Lumpur, Malaysia. They stayed there illegally for seven days, and then flew to Canada after a one-day stopover in Tokyo. The applicants had been travel-
ling on what Immigration Officials determined to be a forged, damaged Saudi passport.
In the course of the examination, Mrs. Smith was found to be in possession of an address book, on one page of which the following was written in Arabic (the translation is that provided by the Minister of Employment and Immigration and the Canadian Security Intelligence Service (CSIS)):
Missile 10 dinars Explosive fuses
Bullets for a submachine gun 120 fels
Bullets for a heavy submachine gun 150 fels
Thagar black 17 dinars
Tracer bullets 30 dinars
The address book also contained several addresses and telephone numbers, and a number of handwritten phrases in Arabic. One of these phrases was translated by CSIS as follows:
We will put the utmost terror in the hearts of the infidels who believe in more than one God.
Mrs. Smith also had an identification card bear ing her alias in Iraq as a member of the Islamic Union of Iraqi Students, which CSIS believes is linked to the Al -Dawa organization.
A search was conducted of the applicants' lug gage, which yielded, inter alia, a false Iraqi pass port, letters apparently written by the Iraqi secret police indicating that a decision had been made to arrest Mr. Smith for treason, and an identification card indicating that Mr. Smith was a member of the Islamic Revolutionary Guards, a division of the Iranian military. In addition, literature and pamphlets apparently published by the Al -Dawa party were found. Upon the discovery of these items, the applicants were questioned by officers of CSIS about the circumstances of their arrival in Canada and their relationship to Al -Dawa.
Al -Dawa
At this point, it would be useful to review the information made available to the Court about
Al -Dawa. According to the evidence provided by the respondent, consisting mainly of magazine and newspaper articles and extracts from reference books already in the public forum, Al -Dawa is a militant, fundamentalist Shiite Islamic organiza tion which is opposed to the relatively secularist Baath Party regime of Saddam Hussein and aligned with the Islamic revolutionary government in Iran. With the outbreak of war between Iraq and Iran in 1980, Baghdad deported thousands of Shiites to Iran from southern Iraq, where they form a majority. Some of these Iraqi exiles engaged in terrorist operations organized by Al -Dawa against Iraq, with the support of the Iranian government. Al -Dawa is currently based in Iran, but continues to function underground in Iraq where it has engaged in bombings and hijack ings against the Hussein government and other Middle East states.
CSIS believes that Al -Dawa has been involved in terrorist attacks against Western interests in the Middle East, in particular bomb attacks in 1983 against the French and American embassies in Kuwait. CSIS believes that these attacks were carried out with the support and encouragement of Iran. It also states that Al -Dawa has cooperated in terrorist activities with the Lebanese Hizballah group, a fundamentalist Shiite group that has also been linked to Iran.
Interview with CSIS
The record of the interview reveals that Mr. Smith was very forthcoming in his response to the questions of the CSIS officers about his associa tion with Al -Dawa. It should be noted that the respondent has admitted that the CSIS officers did not advise the applicants of, nor accord them, an opportunity to retain and instruct counsel before this interview. However, because of the ultimate conclusion I have reached in this matter, I do not think it necessary to consider any possible Charter [Canadian Charter of Rights and Freedoms, being Part I of the Constitution Act, 1982, Schedule B, Canada Act 1982, 1982, c. 11 (U.K.) [R.S.C., 1985, Appendix II, No. 44] ] violations arising out of this admission. In any case, in my opinion this is a case where unrestrained candour on the part of
the applicants has worked to their advantage despite the absence of counsel.
Mr. Smith stated that he first became involved with the party in Iraq in 1979, distributing leaflets on its behalf and participating in demonstrations. After the beginning of the Iran-Iraq war in 1980, the Hussein government believed that Iran was supporting Shiite opposition groups like Al -Dawa in order to destabilize the Iraqi regime. The Iraqi secret police were directed to search out and jail these Shiite fundamentalists. Those who were found to be Al -Dawa members were executed. Mr. Smith was arrested and jailed in 1981. He could not be directly linked to Al -Dawa, however, and he was released in 1983.
After his release, Mr. Smith fled Iraq for Iran. As an Iraqi, he required a government-approved sponsor to stay in Iran during the war. Mr. Smith was sponsored by the Al -Dawa party. At this time, he took an alias to protect his family in Iraq in case his association with Al -Dawa became known to the Iraqi government through Iraqi informers and agents. While in Iran, he volunteered for service in the Islamic Revolutionary Guards, and after a brief period of military training fought against Iraq for three months in 1984. He then returned to Tehran, where he worked for a maga zine for a year.
Mr. Smith then became active in the Al -Dawa again and volunteered to go to an Al -Dawa base in Kurdistan in Iraq, which was to serve as a base for sabotage actions against Iraqi facilities. Mr. Smith told CSIS that he did not take part in any sabo tage missions, his role being to provide religious guidance to the local Kurds. CSIS asked him why he had been given this responsibility, as he had no formal religious training. He stated that he pro vided instruction at a very basic level, as the Kurdish peasants had only a very rudimentary knowledge of their religion. He spent a year at the base, during which a limited number of missions were launched against Iraq, only one of which was
successful. He stated that he did not know the true identities of the saboteurs, presumably a precau tion taken against infiltration by Iraqi agents, and had very little knowledge of their training.
In 1986, Mr. Smith was released from his duty at the base and spent six months in the Iranian city of Qom. Here he met and married Mrs. Smith in 1987. Mrs. Smith had left Iraq in 1980, and had moved to Iran after three years spent in Syria as a legal visitor. They then returned to Tehran, where Mr. Smith took up his former position with the magazine.
With the end of the Iran-Iraq war in 1988, relations between the former enemies began to improve. Relations improved further after the Iraqi invasion of Kuwait in 1990, and Mr. Smith stated that he and other members of the Iraqi exile community had been warned that one of the terms of this rapprochement was that Iraqi exiles in Iran would be forcibly repatriated to Iraq. He feared that as an opponent of the Hussein regime his life would be in danger should he be returned to Iraq. He also stated that he feared that an Iraqi embassy which had recently opened in Tehran would be used to identify and eliminate dissidents exiled in Iran.
Mr. Smith said he then decided to flee to Canada based on its reputation as a free and democratic society. He borrowed money and bought the false Iraqi and Saudi passports and plane tickets to Canada. The passports were made out under the aliases the Smiths had used while in Iran. A friend in Tehran provided him with the names of people to contact in Toronto, who might be able to assist him on arrival.
CSIS officers asked Mr. Smith to explain the references to weapons in the address book. He stated that he had compiled the list in 1986 when he was at the Al -Dawa base in Iraq. He had been approached by a Kurdish arms merchant, who knew Mr. Smith to be an Al -Dawa member. The
merchant asked Mr. Smith to record the prices of some of his inventory should Al -Dawa be interest ed in purchasing some. Mr. Smith said he had passed this information on to his colleagues in the military section of the base, and did not know if any purchases had taken place.
CSIS also asked Mr. Smith to explain the Arabic statement in the notebook concerning the "infidels". He stated that it was a Koranic verse, which was used by members of Al -Dawa as pass words amongst themselves. This particular pass word had been given to him before he had left the base in Iraq for Qom, and was to be used when contacting other Al -Dawa members when he arrived in the city. He stated that he had written the verse in the notebook so he would be able to recall it when he arrived in Qom.
Mr. Smith concluded the interview by advising the CSIS officers that he had come to Canada for peaceful reasons, and had no intention of rejoining Al -Dawa if he were allowed to remain in Canada.
DETENTION OF THE SMITHS
A decision was made to detain the Smiths for seven days pursuant to paragraph 103.1(1)(a) [as enacted by R.S.C., 1985 (4th Supp.), c. 29, s. 12] of the Act, on the grounds that they had not satisfied the immigration officer as to their identi ty, and that they suspected the Smiths to be members of an inadmissible class. The Smiths were ordered detained in separate detention cen tres. The detention was ordered to be continued by a senior immigration officer on January 16, 1991 after review by an adjudicator.
On January 23, 1991, the Minister of Employ ment and Immigration issued a certificate under subsection 103.1(2) [as enacted idem] of the Act stating that the identity of the applicants had not yet been established, and that the Minister had reason to suspect that they were members of an inadmissible class of persons. The Minister stated that a further period of detention was necessary to investigate these matters, and the applicants were then brought before another adjudicator pursuant to subsection 103.1(5) [as enacted idem] of the Act in order to determine if reasonable efforts of
investigation were being made by the Minister that would warrant their continued detention.
Hearing Before the Adjudicator—January 23-24, 1991
At the hearing, a senior immigration officer stated that the applicants were being investigated by the Canadian Security and Intelligence Service (CSIS) as possible security risks, on the grounds that they had entered Canada on forged docu ments, that Mr. Smith had admitted his associa tion with Al -Dawa, and that he had been in posses sion of the weapons list in the notebook. The officer acknowledged that Al -Dawa did not sup port the current Iraqi government, but submitted that given the state of war between the United Nations Alliance and Iraq, it was conceivable that the applicants might act on behalf of Iraq in Canada should the war begin to go badly for Iraq. The officer offered his assurance to the adjudica tor that an active investigation of the applicants was being carried out by CSIS, and that he had a report by CSIS in his possession, but declined to produce it or any other evidence of the investiga tive efforts at the hearing.
The adjudicator determined that the Minister had not satisfied him that reasonable efforts were being made to investigate the identities of the applicants or their alleged membership in an inad missible class, as the immigration officer had pro vided no factual basis for him to determine if the efforts were reasonable. He therefore refused to order continuing detention under subsection 103.1(5) of the Act. He stated that while the facts provided by the immigration officer may have warranted the initial detention, they did not consti tute reasonable investigative efforts that would justify continued detention.
The immigration officer then argued that the adjudicator should order the continued detention of the applicants under paragraph 103(3)(b) [as am. by R.S.C., 1985 (4th Supp.), c. 28, s. 27] of the Act on the ground that the applicants posed a danger to the public. In support of this position he submitted that the applicants were members of a
terrorist group that CSIS had determined was hostile to the West, that they did not have valid identification, and referred to the inscriptions referring to weapons and "striking terror" in the address book.
Counsel for the applicants stated that the CSIS information about Al -Dawa was erroneous and outdated. He submitted that the applicants posed no threat to Canada because of their membership in Al -Dawa, and that the applicants' association with Al -Dawa was the reason they sought refuge in Canada in the first place. He observed that Mr. Smith had spent two years in prison for opposition to the Iraqi government, which bolstered the credi bility of his refugee claim. He argued that anyone entering Canada intending to engage in terrorism would be unlikely to carry with them literature about their cause, or enter on forged, damaged passports. As for the inscriptions in the address book, he submitted that Mr. Smith had provided candid, credible explanations for them. As for Mrs. Smith, she was now pregnant, and unlikely to constitute a danger to Canada.
The adjudicator ordered that the applicants be released on conditions. He stated that he could not conclude on the evidence provided that the appli cants posed a danger to the public. He acknowl edged that Al -Dawa was opposed to the Iraqi government and had probably engaged in armed opposition to it. However, he stated that the Min ister had failed to provide any evidence beyond the assertion of the immigration officer that Al -Dawa was likely to engage in activities against North America or other members of the Alliance. In addition, he found that there was no evidence that the applicants themselves had ever engaged in terrorism, and that even if Mr. Smith had engaged in armed resistance to the Iraqi regime in the past, there was no evidence that he would engage in violent acts while in Canada. The adjudicator also found that the explanations provided by Mr. Smith as to the address book were credible and consistent
with his claim for refugee status as an opponent of the Iraqi government.
CERTIFICATE UNDER SUBSECTION 40.1(1) OF THE ACT
On January 25, 1991, the Minister of Employ ment and Immigration and the Solicitor General filed a certificate with a senior immigration offi cer, acting under section 40.1 [as enacted by R.S.C., 1985 (4th Supp.), c. 29, s. 4] of the Act, which states (in the provisions relevant to this proceeding):
40.1 (1) Notwithstanding anything in this Act, where the Minister and the Solicitor General are of the opinion, based on security or criminal intelligence reports received and considered by them, that a person, other than a Canadian citizen or permanent resident, is a person described in paragraph 19(1)(d),(e),(f),(g) or (j) or 27(2)(c), they may sign and file a certificate to that effect with an immigration officer, a senior immigration officer or an adjudicator.
(2) Where a certificate is signed and filed in accordance with subsection (1), an inquiry under this Act concerning the person in respect of whom the certificate is filed shall not be com menced, or if commenced shall be adjourned, until the determi nation referred to in paragraph (4)(d) has been made and a senior immigration officer or an adjudicator shall, notwith standing section 23 or 103, detain or make an order to detain the person named in the certificate until the making of the determination.
(3) Where a certificate referred to in subsection (1) is filed in accordance with that subsection, the Minister shall
(a) forthwith cause a copy of the certificate to be referred to the Federal Court for a determination as to whether the certificate should be quashed; and
(b) within three days after the certificate has been filed, cause a notice to be sent to the person named in the certificate informing the person that a certificate under this section has been filed and that following a reference to the Federal Court a deportation order may be made against the person.
(4) Where a certificate is referred to the Federal Court pursuant to subsection (3), the Chief Justice of that Court or a judge of that Court designated by the Chief Justice for the purposes of this section shall
(a) examine within seven days, in camera, the security or criminal intelligence reports considered by the Minister and the Solicitor General and hear any other evidence or infor mation that may be presented by or on behalf of those Ministers and may, on the request of the Minister or the Solicitor General, hear all or part of such evidence or infor mation in the absence of the person named in the certificate and any counsel representing the person where, in the opinion of the Chief Justice or the designated judge, as the case may be, the evidence or information should not be disclosed on the
grounds that the disclosure would be injurious to national security or to the safety of persons;
(b) provide the person named in the certificate with a statement summarizing such information available to the Chief Justice or the designated judge, as the case may be, as will enable the person to be reasonably informed of the circumstances giving rise to the issue of the certificate, having regard to whether, in the opinion of the Chief Justice or the designated judge, as the case may be, the information should not be disclosed on the grounds that the disclosure would be injurious to national security or to the safety of persons;
(c) provide the person named in the certificate with a reason able opportunity to be heard;
(d) determine whether the certificate filed by the Minister and the Solicitor General is reasonable on the basis of the evidence and information available to the Chief Justice or the designated judge, as the case may be, and, if found not to be reasonable, quash the certificate; and
(e) notify the Minister, the Solicitor General and the person named in the certificate of the determination made pursuant to paragraph (d).
(5) For the purposes of subsection (4), the Chief Justice or the designated judge may receive and accept such evidence or information as the Chief Justice or the designated judge sees fit, whether or not the evidence or information is or would be admissible in a court of law.
(6) A determination under paragraph (4)(d) is not subject to appeal or review by any court
(7) Where a certificate has been reviewed by the Federal Court pursuant to subsection (4) and has not been quashed under paragraph (4)(d),
(a) the certificate is conclusive proof that the person named in the certificate is a person described in paragraph 19(1)(d),(e),(f),(g) or (j) or 27(2)(c); and,
(b) the person named in the certificate shall, notwithstanding section 23 or 103, continue to be detained until the person is removed from Canada.
A detention order was then issued in respect of the applicants by a senior immigration officer.
Section 41 [now section 40.1] was enacted by An Act to amend the Immigration Act, 1976 and the Criminal Code in consequence thereof, S.C. 1988, c. 36, s. 4 now R.S.C., 1985 (4th Supp.), c. 29, s. 4, and proclaimed in force October 3, 1988. Section 40.1 provides for a form of judicial review in the case of an applicant for refugee status who is not a permanent resident of Canada and who for security or other specified reasons may not be admitted to Canada. The concerned ministers file with this Court a certificate of their conclusion that a person does not qualify for admission, for review by the Court to determine whether the certificate is reasonable on the evidence and infor mation provided to the judge. Until this determi-
nation is made, and the certificate either quashed or approved, any inquiry into the refugee status of the applicant may not be commenced, or if already commenced it must be adjourned.
On January 31, 1991, I conducted a hearing during which I examined the security intelligence reports considered by the Minister and the Solici tor General. I also heard other evidence presented by a CSIS officer, Gregory Pearce. Following this hearing I signed an order that extended the time to serve the applicants with notice of the proceedings pursuant to paragraph 40.1(3)(b) to January 29, 1991, four days after the certificate had been filed instead of the three days provided for in paragraph 40.1(3)(b). The order also provided that the respondents be allowed to advance the evidence of Gregory Pearce, that the hearing be conducted in camera in the absence of the persons named in the certificate and their counsel and that the security intelligence reports be sealed and kept separate and apart from other public court files. I examined a summary of the information provided to me which had been prepared by CSIS, vetted it and ordered it served on the applicants. I then sched uled February 5, 1991 as the date on which the applicants would have their "reasonable opportu nity to be heard".
HEARINGS OF FEBRUARY 5 AND 12, 1991
The hearing was held in open court on the request of the applicants, which was not objected to by the respondent. I also ordered, on the request of the applicants and without objection from the respondent, that in the best interests of the appli cants that they be referred to in these proceedings by the pseudonyms Joseph Smith and Sarah Smith.
At the hearing, counsel for the applicants attempted to move before me a motion by way of certiorari to quash the order of detention made by the senior immigration officer on January 25, 1991. However, as leave for the motion had not been obtained I refused to allow the motion to be filed at the hearing. Counsel for the applicants
then stated that he would seek leave to file the motion in the ordinary course as an application separate and apart from these proceedings under section 40.1 of the Act.
At the hearing, the applicants made a number of preliminary objections about the procedures fol lowed by the Court and the respondent in this matter, which the applicants submitted affected the jurisdiction of the Court to consider the rea sonableness of the certificates. These objections are as follows:
(a) That the order I made to extend time for service of notice to the applicants was made without jurisdiction, and that compli ance with the notice requirements of subsection 40.1(3) is a condition precedent to the jurisdiction of this Court over the subject-matter of this proceeding;
(b) That the Court had no jurisdiction to make the order extending time or the other orders on an ex parte basis;
(c) That the decision of the Court to hear the additional evidence of Gregory Pearce in camera should not have been made in camera;
(d) That the summary provided to the applicants did not comply with paragraph 40.1(4)(b) of the Act, as it had not been drafted by the designated judge personally;
(e) That the reference of the certificate to the Federal Court was not filed "forthwith" as required by paragraph 40.1(3)(a) of the Act;
(f) That the Court should order that fuller disclosure be provided to the applicants of the sealed documents, that full details be provided of all evidence heard in camera, that the ink and paper in the address book be dated by forensic science techniques, that the CSIS officers who interviewed the appli cants be made available for cross-examination, that the transla tor of the materials be produced for cross-examination, and that the complete CSIS file on Al -Dawa be produced for use by the applicants.
The matter was then adjourned to February 12, 1991, when the submissions of the parties on the preliminary objections were heard. Following argument on these issues I reserved my decision. It was agreed at that time that if I found no merit in the preliminary objections, the applicants would have their "reasonable opportunity to be heard" provided by paragraph 40.1(4)(c) of the Act on March 26, 1991. With respect to the issue of more extensive disclosure, counsel for both parties undertook to consult with each other as to whether they could agree on terms by which the evidence of the CSIS officers could be placed before the Court. The Court was subsequently advised by letter dated February 22, 1991 that they were not
able to come to an agreement. With regard to the issue of the age of the ink and paper in the notebook, the respondent stated that it was pre pared to accept the admission of Mr. Smith that the address book had been most recently used in 1986.
PRELIMINARY OBJECTIONS
The objections by the applicants are directed towards the jurisdiction of this Court to hear the merits of the case. While my ultimate conclusion as to the reasonableness of the certificate tend to make most of the issues raised in the following analysis academic, I feel that they must be addressed as the jurisdiction of the Court to make the ultimate determination of reasonableness has been challenged.
1. Order to Extend Time
The respondent put forward several arguments to counter the submission of the applicants that this Court has no jurisdiction to grant an extension of time. First, the respondent submitted that com pliance with the notice provisions in paragraph 40.1(3)(b) is not a condition precedent to the Court having jurisdiction to consider the reason ableness of the certificate. The respondent further argued that the word "shall" in the context of the notice provisions should be read as having directo ry and not mandatory import in this particular context. In the alternative, it was submitted that the Court had the implied power to extend time in order for it to effectively exercise the review juris diction over the certificate expressly granted by the Act. Finally, the respondent submits that the computation of time provisions in the Federal Court Rules [C.R.C., c. 663] should apply to this proceeding.
I agree with the respondent's submission that compliance with the notice provision is not a pre condition to the exercise of its review function under subsection 40.1(4). It should be noted that under paragraph 40.1(4)(a), the Court is required to conduct the in camera review within seven days of the referral of the certificate to the Court under subsection 40.1(3). The referral to the Court is to
be made "forthwith" after the filing of the certifi cate with the appropriate immigration official under subsection 40.1(1). The person named in the certificate is to be notified that a certificate has been filed within three days of it being filed. It is therefore possible that a certificate could be filed, referred to the Court and reviewed before the three-day notice provision has expired. It is true that in this case, the applicants were not notified until four days had elapsed from the date the certificate was filed, and that the review by the Court was conducted six days later. However, it still must be observed that the statute contem plates that in some circumstances, a review may be conducted before the person named in the certifi cate need be notified of the fact that a certificate has been filed. I would therefore conclude from the above that it was not the intention of Parliament that strict observance of the notice provisions is a pre-condition to the judicial consideration of the certificate under subsection 40.1(4).
I am also satisfied that the respondent is correct in submitting that the word "shall" in subsection 40.1(3) should be read as being directory and not mandatory. Jones and de Villars, in their text Principles of Administrative Law (1985, Carswell) observe at page 111 that in determining whether a statutory requirement is mandatory or directory, the Court should consider
... the policy of the Act, all of its provisions, the reason for including the specific statutory requirement in question, wheth er any statutory consequence is provided for failure to comply, and what the practical effect of non-compliance is on the complainant or any other person.
In my view, the legislative framework concern ing time limits was intended to be directory and not mandatory. The policy and purpose of the Immigration Act, as set out in section 2 of the Act, balances the security interests of the state with the individual rights of the parties seeking entry to Canada, and thus could be construed as supporting either characterization. However, while statutory provisions should be observed if at all possible, it may not always be practical in circumstances where national security is at risk to require strict compliance where there is no serious prejudice to the person named. In addition, there is no specific consequence provided for the failure to provide
notice. As there is no basis for participation by the person named in the certificate until after the in camera review, the failure of the respondent to notify the applicants within the prescribed three- day period has not seriously prejudiced them in the circumstances of this case. This does not mean, however, that significant delays in meeting the statutory notice requirement should be excused by the Court as mere irregularities. It would appear that the purpose of this particular notice require ment in the Act is to ensure that a person named in a certificate is aware of the reason for his or her continued detention, and also of the fact that they may face deportation. In my view, these are sig nificant interests that should be protected, and departures from the statutory standard should only be condoned where there has been substantial compliance with the three-day provision and a lack of prejudice to the named person's interests. In this case, the delay in providing notice to the applicants was one day, which is not significant nor unduly prejudicial in the circumstances.
I would therefore conclude that based on the foregoing, the jurisdiction of the Court to consider the reasonableness of the certificate has not been affected by the failure of the respondents to strict ly observe the notice requirements. It is therefore unnecessary to consider the alternative grounds put forward by the respondent on this issue.
2. Ex Parte Proceedings
Counsel for the applicants submits that there was no jurisdiction for the Court to have made the order extending time, nor the other elements of the order, on an ex parte basis. In support of this submission, he relies on Neal v. A.G. (Sask.) et al., [1977] 2 S.C.R. 624, a case in which the Supreme Court of Canada ruled that an application by the Crown for extension of time to file an appeal against an acquittal in a summary conviction case obtained ex parte should be set aside.
I am unable to see any merit in this submission. In my opinion, the case at hand is easily distin guishable from that in the Neal case. It is trite law that the normal practice in any legal proceeding is to provide notice to the other side, and an opportu nity to make submissions. However, in this case, I believe that paragraph 40.1(4)(a) of the Act pro vides the Court with the jurisdiction to proceed ex parte. Unlike the situation in Neal, the statute in this case clearly provides the presiding judge with the discretion to hear all or part of the evidence or information presented in the absence of the person named in the certificate or their counsel if the disclosure of such evidence would be injurious to national security or the safety of persons. In my opinion, this right to exclude would by implication extend to the making of orders necessarily inciden tal to the exercise of this discretion, and therefore the judge need not hear submissions on these orders. In this case, the order to hear the evidence of Gregory Pearce in camera was incidental to the decision that the evidence should not be disclosed, which is a determination that the judge is express ly authorized to make. Similar points could be made with respect to the orders to conduct the entire hearing in camera, to seal the reports, and providing an edited summary. As for the order to extend time, I am satisfied that this could also be conducted in camera as part of the overall pro ceedings, and in any event for the reasons given above no prejudice resulted from the lack of oppor tunity to make submissions on this point.
3. In Camera Proceedings
The applicants submit that section 40.1 only authorizes in camera examination of the security reports considered by the Ministers, and other information like the oral evidence of Pearce in limited circumstances. They also submit that the decision to allow further evidence to be called in camera cannot be made in camera.
In my opinion, this submission is also without merit. Paragraph 40.1(4) (a) expressly authorizes a
judge to "hear any other evidence or information" in camera in his discretion for national, security reasons. There is no reason to exclude oral evi dence from the scope of this provision. As for the submission that this decision cannot itself be made in camera, I would dispose of this argument for the same reasons as put forward in the section on ex parte proceedings.
4. The Summary
The applicants further submit that the state ment summarizing the information necessary for the applicants to be reasonably informed of the circumstances giving rise to the certificate must be prepared by the judge himself. There is no express requirement in paragraph 40.1(4) (b) that the sum mary be prepared by the judge himself, and I would not read one in the absence of compelling reasons to do so. In my opinion, the function of the judge in this case is to ensure that the person named has been reasonably informed. In this case, I examined and approved the report of the evi dence available to me, and in my discretion ordered parts edited from the summary in the interests of national security without prejudicing the applicants' right to be reasonably informed. I would also note that editing of information pro vided to the Court occurs in analogous judicial situations, such as the affidavits of police inform ers when access is sought to the sealed packet in a wiretap case: see R. v. Garofoli, [1990] 2 S.C.R. 1421.
5. "Forthwith"
The applicants also submit that as the reference of the certificate was not made to the Federal Court until four days had elapsed since the filing of the certificate, it was not referred "forthwith" as required by paragraph 40.1(3)(a) of the Act.
The meaning of "forthwith" was considered by the Ontario Court of Appeal in R. v. Parrot (1979), 27 O.R. (2d) 333. The accused union leader was required by back-to-work legislation to give notice "forthwith" to his workers that a strike
had become invalid. The Court considered the meaning of "forthwith", at pages 339-340:
Finally, ... we are satisfied that the word "forthwith" in s. 3(1) of the statute must be read as meaning "immediately" or "as soon as possible in the circumstances, the nature of the act to be done being taken into account": 37 Hals., 3d. ed., p. 103; or "as promptly as is reasonably possible or practicable under all the circumstances": R. v. Bell, [ 1969] 2 C.C.C. 9 at p. 18 ... .
Reference to all reported cases seem to support the twin proposition that "forthwith" does not mean instantly (R. v. Cuthbertson, supra), but, rather, without any unreasonable delay, considering "the objects of the rule and the circum stances of the case": per Jessel M.R., Ex parte Lamb (1881), 19 Ch. D. 169 at p. 173 .... See also Mihm et al. v. Minister of Manpower & Immigration, [ 1970] S.C.R. 348 at p. 358... .
In this case, I am satisfied that the certificate was referred to the Court as soon as was reasonably possible in the circumstances. It is of course desir able that in a case in which the liberty of an individual is at stake, that the matter be brought before the Court with all reasonable speed. In this case, it was necessary for the respondent to gather the necessary evidence and information to be pre sented before the Court. Such research necessarily takes time from the time that the certificate was issued, and in this case, when part of the time took place over a weekend, I am satisfied that the time taken was reasonable in the circumstances. I would note that the statute provides that the secu rity and intelligence and other reports should be examined by the Court within seven days of the issuance of the certificate, and in this case the four days that did elapse still left the Court with suffi cient time to adequately examine the evidence.
6. Greater Disclosure
As noted above, the applicants sought greater disclosure of the material that was before the Court in the in camera hearing. They sought full disclosure of the documents in the sealed files, that full details be given of the evidence provided by witnesses at the hearing, and that the author of the written material submitted before me be produced for cross-examination. They also requested that
the officers who searched and questioned the applicants and the translator be made available for cross-examination. They also submitted that any files that CSIS may have on Al -Dawa be produced for examination by the applicants.
The respondent stated at the hearing that it was opposed to producing the CSIS officers who inter viewed the applicants for cross-examination, but that the respondent would be prepared to allow the applicants to submit written questions concerning any potential Charter violations or other irregularities which may have occurred during the course of the interview, which the officers would answer by affidavit. The respondent opposed the request for production of any sealed documents, files or other excluded evidence from the hearing on the ground that they could not be disclosed for reasons of national security. For the same reason, the respondent objected to producing the CSIS translator for cross-examination. As for the request to cross-examine the author of the written material, this was considered acceptable as long as the cross-examination was limited to matters that did not enter the realm of national security.
Subsection 40.1(4) of the Act gives me as a judge sitting on review of the certificate the discre tion to determine whether any part of the informa tion or evidence before me should not be disclosed on the grounds that the disclosure would be injuri ous to national security or the safety of persons. I was satisfied that in the circumstances, the disclo sure of the sealed file material would be injurious to national security. In this respect, I adopt the remarks of Addy J. in Henrie v. Canada (Security Intelligence Review Committee), [1989] 2 F.C. 229 (T.D.), at pages 242-243 as appropriate guide lines for the exercise of this discretion:
It is of some importance to realize that an "informed read er", that is, a person who is both knowledgeable regarding security matters and is a member of or associated with a group which constitutes a threat or a potential threat to the security of Canada, will be quite familiar with the minute details of its
organization and of the ramifications of its operations regard ing which our security service might well be relatively unin formed. As a result, such an informed reader may at times, by fitting a piece of apparently innocuous information into the general picture which he has before him, be in a position to arrive at some damaging deductions regarding the investigation of a particular threat or of many other threats to national security. He might, for instance, be in a position to determine one or more of the following: (1) the duration, scope, intensity and degree of success or of lack of success of an investigation; (2) the investigative techniques of the service; (3) the typo graphic and teleprinter systems employed by CSIS; (4) internal security procedures; (5) the nature and content of other classi fied documents; (6) the identities of service personnel or of other persons involved in an investigation.
For these reasons, it is not possible to comment directly on the reasons for sealing the particular documents in this case, as my comments could serve to identify the evidence and other factors listed by Addy J. The same considerations would apply to the applicants' request to produce the persons requested for cross-examination. The applicants cite R. v. Garofoli, supra, as authority for their request to have the CSIS officers pro duced for cross-examination. In Garofoli, the sit uation is distinguishable, because while there was concern over the secrecy and efficacy of police investigations, there was no corresponding national security concern.
It is still possible that the process under section 40.1 may violate the Charter. The issue of whether the procedure for review of the security certificate, disclosure of evidence and detention set out in section 40.1 of the Act violates section 7 of the Charter was referred to in oral argument at the hearing, but no detailed submissions were made on this point. It is probable that a detailed Charter argument was to be made by the applicants at the hearing scheduled for March 26, 1991, their "rea- sonable opportunity to be heard". I have come to the conclusion, however, that it is not necessary to provide the applicants with additional time to con stitute reasonable opportunity to be heard, beyond the submissions already made, because it appears to me that the Minister has not demonstrated that the certificate was reasonable on the basis of the evidence before me. As the Charter issues have not been argued in detail, and no evidence has been lead under section 1, I express no opinion as to
whether section 40.1 could withstand Charter scrutiny.
REASONABLENESS OF THE CERTIFICATE
Having concluded that I have jurisdiction to make this determination it might reasonably have been expected that we would now move under paragraph 40.1(4)(c) to provide the persons named in the certificate with a reasonable oppor tunity to be heard and in fact that was to take place on 26 March 1991. However, having exam ined the issues involved in some considerable detail and having heard the case for applicants, I can find no need to hear from the detainees because the substantive issue can be determined now.
DECISION
The first step is to determine the appropriate meaning to be accorded to the word "reasonable" in paragraph 40.1(4)(d). In judicial review of administrative action, the role of the Court is usually not to review the merits of the decision, but rather to determine whether the decision-maker has acted in accordance with the law. Usually, if there is an express requirement of reasonable con duct in the relevant statute, the official if chal lenged must justify the decision by providing evi dence that would demonstrate that there was a rational basis for his decision, and that he did not base his conclusion on irrelevant considerations. An example of the relatively restrictive approach to reasonableness is found in the decision of Lord Diplock in Secretary of State for Education and Science v. Tameside Metropolitan Borough Coun cil, [1977] A.C. 1014 (H.L.), at page 1064, where he stated that a statutory requirement that a public authority exercise a discretion "reasonably" should be regarded as proscribing "conduct which no sensible authority acting with due appreciation of its responsibilities would have decided to adopt".
In my opinion, however, a higher standard of proof of reasonableness should be applied in cases where an interest in personal liberty is at stake. In Reg. v. Secretary of State for the Home Depart ment, Ex parte Khawaja, [1984] A.C. 74, the House of Lords considered certain provisions of the British Immigration Act [(U.K.), 1971, c. 77] and held that if an immigration officer ordered the detention of any person as an illegal entrant, it would not be sufficient merely to show some reasonable grounds for the action. As a liberty interest was at stake in the detention, the immigra tion officer had to satisfy a civil standard of proof to a high degree of probability that the detained person was an illegal entrant. As Lord Scarman stated for the majority, at pages 113-114:
My Lords, I would adopt as appropriate to cases of restraint put by the executive upon the liberty of the individual the civil standard flexibly applied .... It is not necessary to import into the civil proceedings of judicial review the formula devised by judges for the guidance of juries in criminal cases. Liberty is at stake: that is, as the court recognised in Bater v. Bater [1951] P. 35 and in Hornal v. Neuberger Products Ltd. [1957] 1 Q.B. 247, a grave matter. The reviewing court will therefore require to be satisfied that the facts which are required for the justifi cation of the restraint put upon liberty do exist. The flexibility of the civil standard of proof suffices to ensure that the court will require the high degree of probability which is appropriate to what is at stake. " ... the nature and gravity of an issue necessarily determines the manner of attaining reasonable satisfaction of the truth of the issue": Dixon J. in Wright v. Wright (1948) 77 C.L.R. 191, 210. I would, therefore, adopt the civil standard flexibly applied in the way described in the case law to which I have referred. And I completely agree with the observation made by my noble and learned friend, Lord Bridge of Harwich, that the difficulties of proof in many immigration cases afford no valid ground for lowering the standard of proof required.
Applying the standard set in Khawaja, it is apparent to me that the certificate issued under section 40.1 is not reasonable and should therefore be quashed. I do not find that there is sufficient evidence on the standard set out in Khawaja for the Minister to have concluded that the applicants were members of the inadmissible classes described in paragraphs 19(1)(f) and 19(1)(g) of the Act. There are insufficient grounds to believe that the applicants will attempt to instigate the
subversion by force of any government while in Canada. The connection of the applicants with Al -Dawa, which they freely admitted, is in my opinion an insufficient basis on which to conclude that the applicants will engage in subversion with out substantial evidence that they as individuals would engage in subversion while in Canada. The evidence provided by the respondent dealt with the suspected activities of Al -Dawa, but did not pro vide any evidence as to the potential for subversive activities by the applicants as individuals. As the adjudicator pointed out, the fact that Mr. Smith may have engaged in armed resistance against Iraq in the past does not mean that he will do so while in Canada. As for the address book, I agree with the adjudicator that the explanations pro vided by the applicants were credible, and con sistent with the refugee claim of the applicants.
I would also conclude that it is not reasonable to consider that the applicants will engage in acts of violence that would endanger people in Canada, or are a member of an organization likely to engage in such activities. There was no evidence provided by the respondent that Al -Dawa has engaged in such activities in Canada, or is likely to in the future. The same could be said of the applicants. The possible inferences that could be drawn from their association with Al -Dawa or the address book are in my opinion insufficient in the absence of more direct, individualized evidence about their likelihood to take part in such activities. In my opinion, it is possible that groups which are involved in terrorism, which it appears that Al -Dawa might be in certain circumstances, are not monolithic, but rather may contain within their ranks those who are less disposed to violence or even totally uninvolved. Without more evidence as to the individual proclivity or involvement of the applicants in terrorism or other violence, I do not believe that further detention is reasonable.
In my opinion, the activities of the applicants are consistent with their claim for refugee status, who often arrive in this country with questionable documentation. The applicants appear to have a genuine refugee claim based upon their opposition to the regime of Saddam Hussein. In any event, it is difficult to believe that if the applicants were intent upon subversion that they would enter Canada with identifying pamphlets, and readily provide immigration officials with a detailed histo ry of their association with a suspect group.
I would therefore direct that the certificate be quashed. The applicants are of course at liberty, should incriminating evidence against either individual come to their attention, to move again under section 40.1, but in the present circum stances the detainees are free to continue with their application for refugee status.
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