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3.     Are Palestinian refugee claimants facing persecution according to the Immigration and Refugee Protection Act?

 

 

 

3.1.        Legal Definition of “Refugee” in Canada[1]

 

Section 3(2)(b) of the Immigration and Refugee Protection Act [2] states that one objective of that Act is to “affirm Canada’s commitment to international efforts to provide assistance to those in need of resettlement.”

 

The Refugee Protection Division (RPD) of the Immigration and Refugee Board (IRB) is responsible for deciding claims for refugee protection made by persons from within Canada. Canada has an obligation to grant protection to refugees and other persons in need of protection under a number of United Nations Conventions, including:

 

·         The 1951 Convention Relating to the Status of Refugees,

·         The 1966 International Covenant on Civil and Political Rights, and;

·         The 1984 Convention Against Torture and Other Cruel, Inhuman and Degrading Treatment or Punishment.

The Refugee Protection Division of the IRB determines whether people who appear before it are "Convention refugees"[3] or “Persons in need of protection”[4]. The decisions are now usually made by a single board member – referred to in this document as an IRB member.

The Immigration and Refugee Protection Act[5], s. 96, states that:

 

96. A Convention refugee is a person who by reason of a well-founded fear of persecution for reasons of race, religion, nationality, membership in a particular social group or political opinion,

 

(a) is outside each of their countries of nationality and is unable or, by reason of that fear, is unwilling to avail themselves of the protection of each of those countries, or

 

(b) not having a country of nationality, is outside their country of former habitual residence and is unable or, by reason of that fear, unwilling to return to that country.

 

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3.2.       Country of Persecution in the case of Palestinian refugee claimants

Once in Canada, the Palestinian refugee claimants are outside their country of former habitual residence as they are in fact stateless, be it in Lebanon or in the Occupied Territories.

According to the case law in Canada:

…former habitual residence implies a situation where a stateless person was admitted to a country with a view to enjoying a period of continuing residence of some duration. […] The claimant must, however, have established a significant period of de facto residence in the country in question.[6]

Palestinian refugee claimants coming from Lebanon have clearly ‘established a significant period of de facto residence’ as they have resided in refugee camps in Lebanon since birth, camps which have existed for over 56 years.

Similarly, Palestinian refugee claimants from the Occupied Territories have resided in cities, villages and refugee camps in their homeland – which is under Israeli military occupation.

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3.3.       Persecution faced by Palestinian refugee claimants

 

As stated by the case law, “to be considered persecution, the mistreatment suffered or anticipated must be serious, i.e. it must constitute a key denial of a core human right.”[7]

 

In determining what is considered persecution the Supreme Court said in Ward v. Canada:[8]

 

Underlying the Convention is the international community’s commitment to the assurance of basic human rights without discrimination. This is indicated in the preamble to the treaty as follows:

 

CONSIDERING that the Charter of the United Nations and the Universal Declaration of Human Rights…have affirmed the principle that human beings shall enjoy fundamental rights and freedoms without discrimination.

            …

Hathaway,…at p.108, thus explains the impact of this general tone on the treaty of refugee law:

 

The dominant view, however, is that refugee law ought to concern itself with actions which deny human dignity in any key way and that the sustained or systemic denial of core human rights is the appropriate standard.

 

Moreover, the court continues to hold that “what constitutes a basic human right is determined by the international community, not by any one country. At the same time, in determining whether anticipated actions would constitute fundamental violations of basic human rights, it is acceptable to consider Canadian law.”[9]

 

As such, the violations committed against the Palestinian refugee claimants, as will be shown in this section, undoubtedly constitute persecution.

 

Furthermore, it is well noted in the case law that “the claimant may be subject to a number of discriminatory or harassing acts. While these acts may individually not be serious enough to constitute persecution, they may cumulatively amount to persecution.”[10] Many of the acts committed against the Palestinian refugee claimants, when investigated individually, amount to persecution and there is also no doubt that the totality of these violations amount to persecution.

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3.3.1.       Palestinian refugees in Lebanon[11]

 

Palestinian refugees in Lebanon are the descendents of Palestinian families who were expelled from their homes in Palestine in 1948. For the past 56 years, Palestinian refugees in Lebanon have continued to live in horrific conditions inside refugee camps. Their right to return to the homes they fled in 1948 continues to be completely denied by Israel, in direct violation of the following international legal instruments:

 

·         UN General Assembly Resolution 194, re-affirmed over 110 times by the United Nations General Assembly since 1948;

·         UN General Assembly Resolution 3236 and 52/62;

·         The 4th Geneva Convention;

·         The Universal Declaration of Human Rights;

·         The International Covenant on Civil and Political Rights, and;

·         The International Convention on the Elimination of All Forms of Racial Discrimination.

 

The denial of this individual and inalienable right has led stateless Palestinian refugees into a life of misery in refugee camps throughout neighboring host countries, and particularly in Lebanon. 

 

It is recognized that Lebanon is in violation of a plethora of basic human rights. In 2003, Amnesty International reported that the treatment of stateless Palestinians in Lebanon is in clear violation of:[12]

 

·         The International Covenant on Economic, Social, and Cultural Rights;

·         The International Covenant on the Elimination of All Forms of Racial Discrimination;

·         The Convention on the Rights of the Child;

·         The International Covenant on Civil and Political Rights;

·         The Convention on the Elimination of All Forms of Discrimination Against Women, and;

·         The Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment.

 

Canada has either ratified or acceded to each of these instruments.

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These violations are the result of the systematic discrimination and persecution of Palestinian refugees in Lebanon, best illustrated by the following:[13]

 

·         No right to employment or social security:

Palestinian refugees are restricted from working in over 70 professions; they are barred de jure from practicing several professions such as law, medicine, pharmacy, and journalism. Furthermore, only 1% of the Palestinians in Lebanon manage to secure the mandatory work permit required by the Lebanese government, in order to benefit from regular jobs. Palestinians are also prohibited from obtaining social security when they are able to secure a job. [See Appendix I, page iii]

 

·         No right of ownership and no right to adequate housing:

Palestinians are restricted from rebuilding or redeveloping refugee camps and are forbidden from owning or inheriting property. [See Appendix I, page iv]

 

·         No freedom of expression and no political rights:

Palestinian refugees have no political rights and, for fear of reprisal, they are often afraid to express their opinions.  [See Appendix I, page v]

 

·         No freedom of association:

Palestinians are not permitted to organize and form associations unless done through a Lebanese citizen. [See Appendix I, page vi]

 

·         Restricted freedom of movement:

Palestinians are subjected to regular identity checks at military checkpoints at the entrance and exit of the refugee camps. [See Appendix I, page vi]

 

·         Restricted access to public education:

Lebanese schools and universities operate on quota-systems that restrict access to Palestinian refugees; only 20% of the Palestinian refugees who apply are able to have access to Lebanese education. [See Appendix I, page vii]

 

·         Limited access to public healthcare:

Public hospitals are largely insufficient, and the majority of the population relies on private hospitals that are too costly for most Palestinians. UNRWA has only been able to provide basic medical services as subsidies for hospitalization have declined due to UNRWA’s financial constraints. [See Appendix I, page viii]

 

·         No legal protection & statelessness:

Due to their particular situation as stateless people, Palestinian refugees in Lebanon have been denied virtually every available means of securing their basic rights. UNRWA’s mandate does not provide protection for Palestinian refugees nor can they appeal to the assistance of UNHCR whose mandate specifically exempts Palestinians from its protection. [See Appendix I, page ix]

 

·         Arbitrary arrest, detention, and harassment:

Palestinians are often victims of arbitrary arrest, detention, and harassment by the state security forces and rival militias in the refugee camps. [See Appendix I, page vi]

 

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3.3.2.       Palestinian refugees from the Occupied Territories[14]

As for the Palestinian refugee claimants from the Occupied Territories, they continue to live under the illegal and brutal Israeli military occupation. The Israeli government, its military occupation, and all actions that derive from such an occupation, are in violation of many U.N. resolutions and International conventions such as:

·         UN resolutions 194, 242, 338, 1397, 1402, and many more;

·         The 4th Geneva Convention;

·         The Hague Regulations (Hague II, Hague IV…);

·         UN Code of Conduct for Law Enforcement Officials;

·         The International Covenant on Civil and Political Rights;

·         The International Covenant of Economic, Social, and Cultural Rights;

·         The Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment;

·         The International Covenant on the Elimination of All Forms of Racial Discrimination, and;

·         The Convention on the Rights of the Child.

 

Canada has ratified or acceded to each of the listed international covenants and conventions.

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The violations committed by the Israeli authorities have systematically discriminated against, persecuted, and shattered the lives of the Palestinians whose fundamental human rights continue to be utterly denied. These violations include:[15]

 

·         Injuries, killings and the use of lethal gunfire:

Between September 2000 and November 2003, over 2,755 Palestinians were killed – of which 460 were children - and 28,000 were injured, the majority of whom are civilians. The principal reason for most deaths is the deliberate policy of allowing lethal gunfire in situations where Israeli soldiers are not in danger. [See Appendix II, page i]

 

·         Shelling, shooting, aerial bombardment and indiscriminate use of violence:

Palestinian communities are frequently subjected to indiscriminate shelling and shooting in residential areas, in some places every night. The indiscriminate use of violence is also illustrated by the use of flechette shells in densely populated areas such as Gaza. [See Appendix II, page ii]

 

·         Extra-judicial assassinations:

From October 2000 to April 2003, the Israeli occupation forces killed more than 230 Palestinians, including 80 children, women and innocent bystanders, in assassination actions. [See Appendix II, page ii]  

 

·         The use of Palestinians as human shields:

Israeli soldiers commonly use Palestinians as human shields i.e. civilians are placed in front of Israeli soldiers as they move toward a target. [See Appendix II, page ii]

 

·         The demolition of hundreds of houses and the destruction of thousands of trees and thousands of acres of agricultural land:

The Israeli army has destroyed an estimated 4000 homes over the past three years, leaving thousands of people homeless, many of whom are women, children and the elderly. Israel has also uprooted thousands of trees, and destroyed thousands of acres of land in the Gaza Strip. In almost all the cases of demolition, the houses were occupied and the residents fled when the bulldozers appeared at their doorsteps. [See Appendix II, page iii]

 

·         Land confiscation & the wall:

Israel is presently building a wall that, when completed, will be over 450 kilometers in length. This is a clear act of territorial annexation which has serious implications as it violates the prohibition on the forcible acquisition of territory and the right to self-determination. [See Appendix II, page iv]

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·         Checkpoints:

There are 300 checkpoints or roadblocks in the occupied West Bank. Every day, thousands of Palestinians must pass through checkpoints in order to travel from home to work, to reach schools and hospitals and to visit friends. Accounts of rudeness, humiliation and brutality at the checkpoints are legion. When at all possible, traveling even a short distance between West Bank towns and villages usually entails a lengthy, costly and potentially dangerous journey for Palestinians. [See Appendix II, page iv]

 

·         Sieges, curfews and closures:

Since September 2000, Israel has imposed a total closure on the Occupied Territories. West Bank towns and villages are placed under 24-hour curfew much too often and for prolonged periods. [See Appendix II, page v]

 

·         Imprisonment, administrative detentions and torture:

28,000 Palestinians have been detained by the Israeli army since the outbreak of the Intifada. Presently, there are approximately 5700 prisoners. There are 66 women prisoners detained in Al-Ramleh prison and about 200 boys under the age of 18 who live under very difficult conditions of detention. Moreover, it is common practice for Israeli security forces to torture Palestinians during interrogation. [See Appendix II, page vi]

 

·         Attacks on medical personnel:

The Israeli army often denies access to ambulances, which often come under attack, and are forced to leave the scene. Between September 2000 and June 2003, the Palestine Red Crescent Society recorded 255 Israeli attacks on ambulances. 118 ambulances have been damaged, some more than once. [See Appendix II, page viii]

 

·         Restricting access to food, causing malnutrition:

The already restricted access to humanitarian aid is worsening and has caused a dramatic decline in the standard of living among Palestinians in the Occupied Territories. 60% of the Palestinian population is living below the poverty level, 22% of Palestinian children under 5 are suffering from malnutrition and 9.3% from acute malnutrition. [See Appendix II, page x]

 

It is important to emphasize that the conflict is not between two states or two armies but between an occupying army and an unprotected population that continues to live under this illegal occupation. Furthermore, all of these violations have been committed against a population of just over 3 million people, a size close to that of the Greater Montreal area.

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3.3.3.       Repetitive and Persistent persecution

 

In order to assess that the mistreatment is actually persecutory for the purposes of refugee determination, “the second criterion is that, generally, the mistreatment must be repetitive and persistent.”[16]

 

In the case of the Palestinian refugees in Lebanon, the persecution is clearly repetitive and persistent and has been for many years. The denial of the fundamental human rights of the Palestinian refugees in Lebanon is not only a result of the actions of state authorities but has been an inherent part of the country’s legislation. “The harsh discriminatory practices by the Lebanese government and the incapacity of UNRWA to fulfill its mandate have driven Palestinian refugees into a situation characterized by abject poverty, isolation, and persecution”.[17] As it is a basic element of Lebanese state policy, the persecution is repetitive and persistent.

 

The persecution of the Palestinian refugee claimants is clearly recurring and persistent in the Occupied Territories. Palestinians have lived under Israeli military occupation in the West Bank and the Gaza Strip for over 36 years and, as such, have been subjected to many atrocities and human rights violations at the hands of the Israeli military forces. These violations have reached an alarming level since the outbreak of the second Intifada on September 28th 2000. As noted by the latest reports of renowned international human rights organizations, the situation continues to worsen.[18]

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3.3.4.      Canadian acknowledgment of danger & persecution

 

There is clear Canadian acknowledgement of the danger and persecution faced by Palestinians in the areas they fled. This acknowledgment is outlined by the travel advisory issued by the Department of Foreign Affairs and International Trade:

 

Canadians should not travel to the West Bank or Gaza Strip, which continue to be affected by serious violence. Canadians in the West Bank and Gaza Strip should leave as they are at high risk. They may, however, encounter difficulties departing these territories during times of Israeli closures or curfew, which are frequent. Crossing points into the West Bank and Gaza and other checkpoints generally remain open, although frequent and unannounced closures and other restrictions are being imposed.[19]

 

Canadians should not visit Palestinian refugee camps (in Lebanon), where the security situation is often tense.[20]

 

Moreover, this acknowledgment is confirmed by the following Canadian statements at the United Nations:

 

The humanitarian situation in the Palestinian territories continues to deteriorate…We have raised serious concerns regarding the humanitarian situation in the Palestinian Territories with the Israeli authorities, and have consistently called on Israel to honour its obligations under international law, including those set out in the Fourth Geneva Convention.[21]

 

…the dire humanitarian and economic situation in the Palestinian territories must be meaningfully addressed. Deepening poverty and malnutrition, particularly among Palestinian women and children, are chilling indications of the seriousness of the current situation. Besides becoming a grinding, daily routine for millions of Palestinians, widespread curfews and closures have impeded humanitarian access to those in need. In accordance with its obligations under international law, Israel must facilitate the delivery of humanitarian aid and ensure that Palestinians have full and unhindered access to basic needs including food, water and medical supplies.[22]

 

Furthermore, Canada chairs the Refugee Working Group of the Multilateral Peace Process on the question of the Palestinian refugees. In May 1997, Canada led a mission to report on the situation of Palestinian refugees in Lebanon. In its final report, the mission concluded:

 

…the Palestinian refugees in Lebanon have the most serious problems… They face problems related to obtaining education beyond the primary level, inadequate access to hospitalization, difficulties in respect of shelter improvement, serious limitations on their access to employment in Lebanon, and restrictions on their ability to return to Lebanon if they travel abroad.[23]

 

Since 1997, according to extensive documentation, the conditions of the Palestinian refugees in Lebanon continued to deteriorate dramatically.[24]

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3.4.       Grounds of Persecution of Palestinian refugee claimants

 

“For the claim to succeed, the persecution must be linked to a Convention ground, in other words, there must be a nexus.”[25] More precisely:

 

… a claimant's fear of persecution must be by reason of one of the five grounds enumerated in the definition of Convention refugee - race, religion, nationality, membership in a particular social group and political opinion. There must be a link between the fear of persecution and one of the five grounds.[26]

 

The Palestinian refugee claimants are persecuted due to their nationality and their particular social group. As stated by the Supreme Court of Canada in Ward,[27] one of the categories that defines ‘particular social groups’ is the existence of an “innate or unchangeable characteristic”.  In Lebanon and in the Occupied Territories, the Palestinian refugee claimants are persecuted solely because they are Palestinian.

 

In fact, “Palestinians in Lebanon are de jure and de facto discriminated against in relation to other non-citizens with regards to the right to work and the right to social security (and) with regards to the rights to own and inherit property”.[28]

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3.5.       Palestinian refugee claimants have a well-founded fear of persecution

 

The next criterion for refugee determination is the existence of a well-founded fear of persecution. “The claimant must establish, on a balance of probabilities, that there are "good grounds" for fearing persecution. This may also be stated as a "reasonable" or even a "serious possibility" as opposed to a mere possibility that the claimant would be persecuted if returned to the country of origin.”[29] Furthermore, “[a] claimant may have a subjective fear that he or she will be persecuted if returned to his or her country, but the fear must be assessed objectively in light of the situation in the country to determine whether it is well founded.”[30]

 

Extensive documentation on the persecution faced by Palestinian refugee claimants in Lebanon and the Occupied Territories clearly proves that their subjective fear is well founded and justified considering the objective situation on the ground. [31]

 

Additionally, “the availability of national protection forms part of the analysis of whether the claimant's fear is well founded.”[32] In the case of the Palestinian refugee claimants, the complete absence of state protection - as shown in the next section - contributes to establishing that their fear is well founded.

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3.6.       State Protection absent in the case of Palestinian refugee claimants

 

Although, “according to paragraph 101 of the UNHCR Handbook, stateless claimants need not avail themselves of state protection since there is no duty on the state to provide protection,”[33] it is nevertheless clear in the case of stateless Palestinian refugee claimants that state protection is completely absent.

 

In Lebanon, because of their unique situation, Palestinian refugees have been denied virtually every available means of securing their basic rights:


The exceptional condition of Palestinian statelessness and Palestinian dispersal extends itself to all political, economic, social and humanitarian spheres. UNRWA's mandate does not provide protection for Palestinian refugees nor can they appeal to the assistance of UNHCR whose mandate specifically exempts them from its protection. This aberration is particularly significant, not only for refugees living under Israeli occupation in the West Bank and Gaza, but also for those Palestinian refugees who are temporary residents in various countries, mainly Lebanon, Syria and Jordan (1). Thus, UNRWA's operations in these countries, the refugees' legal status and their rights are subject to host government policies without recourse to international agreements delineating refugee rights.[34]

 

Furthermore, Palestinian refugee claimants from the West Bank and the Gaza Strip continue to live under Israeli military occupation and are therefore denied any form of legal protection. The international community, including Canada, recognizes the illegality of the continued occupation of Palestinian territories. [35]  

 

In both cases, there is “clear and convincing” evidence of the state’s inability to protect the claimants.[36] In fact, the state is not only unwilling to provide protection but is an agent of persecution against the Palestinians. Thus, the absence of protection from the state is not a contentious issue in the case of Palestinian refugee claimants as they are deprived of all their fundamental rights by the state in question, and have no state of their own providing protection.

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3.7.       Palestinian refugee claimants do not have an Internal Flight Alternative (IFA)

 

As indicated by the Federal Court in Rasaratnam[37] and Thirunavukkarasu[38], the test to be applied in determining whether there is an IFA is two-fold:

 

(1)     …the Board must be satisfied on a balance of probabilities that there is no serious possibility of the claimant being persecuted in the part of the country to which it finds an IFA exists.

 

(2)     Moreover, conditions in the part of the country considered to be an IFA must be such that it would not be unreasonable, in all the circumstances, including those particular to the claimant, for him to seek refuge there.

 

Both of these conditions must be satisfied for a finding that the claimant has an IFA.[39]

 

As such, Palestinian refugee claimants do not have an internal flight alternative as they are persecuted by the persecuting states in all parts of their territory. In the West Bank and the Gaza Strip, the claimants are under military occupation and are persecuted on the entire Territory. Similarly in Lebanon, the claimants face systematic discrimination on all the territory. In fact, Amnesty International has made the following unequivocal observations:

 

Palestinians in Lebanon are de jure and de facto discriminated against as compared with other non-citizens with regards to the rights to own and inherit property, as well as to the right to work and the right to social security…Discrimination levied against Palestinians in relation to the rights to own and inherit property and the right to work, creates conditions where Palestinians refugees cannot enjoy an adequate standard of living. [40]


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[1] Immigration and Refugee Board, Refugee Protection Division, online at <http://www.cisr.gc.ca/en/about/tribunals/rpd/index_e.htm >

[2] Immigration and Refugee Protection Act, S.C. 2001, c. 27.

[3] Convention Relating to the Status of Refugees, 189 U.N.T.S. 2545, 22 April, 1954; Protocol Relating to the Status of Refugees, 606 U.N.T.S. 8791, 4 October, 1967.

[4] Immigration and Refugee Protection Act, S.C. 2001, c. 27, s. 97(1).

[5] Supra note 8.

[6] Maarouf v. Canada (Minister of Employment and Immigration), [1994] 1 F.C. 723 (T.D.)

[7] Canada (Attorney General) v. Ward, [1993] 2 S.C.R. 689, 103 D.L.R. (4th) 1, 20 Imm. L.R. (2d) 85; Chan v. Canada (Minister of Employment and Immigration), [1995] 3 S.C.R. 593.

[8] Ibid.

[9] Ibid.

[10] Madelat, Firouzeh v. M.E.I., Mirzabeglui, Maryam v. M.E.I. (F.C.A., nos. A-537-89 and A-538-89), MacGuigan, Mahoney, Linden, January 28, 1991.

[11] See Appendix I: Persecution faced by Palestinian refugees in Lebanon, below.

[12] Amnesty International, “Lebanon: Economic and Social Rights of Palestinian Refugees”, 2003 Report, online at <http://web.amnesty.org/library/Index/ENGMDE180172003>

[13] Supra note 17.

 

[14] See Appendix II: Persecution faced by Palestinians in Occupied Palestine, below.

[15] Ibid.

[16] Rajudeen, Zahirdeen v. M.E.I. (F.C.A., no. A-1779-83), Heald, Hugessen, Stone, July 4 1984.

[17] Sherifa Shafie, Palestinian Refugees in Lebanon”, Forced Migration Online Research Guide (2003), online at <http://www.forcedmigration.org/guides/fmo018/fmo018.pdf>.

[18] Supra note 20.

[19] Department of Foreign Affairs and International Trade, Travel report - Israel, the West Bank and Gaza – valid as of March 4, 2004. online at <http://www.voyage.gc.ca/dest/report-en.asp?country=135000>.

[20] Department of Foreign Affairs and International Trade, Travel report – Lebanon – valid as of March 4, 2004. online at < http://www.voyage.gc.ca/dest/report-en.asp?country=159000>.

[21]  Department of Foreign Affairs and International Trade, Statement by the Representative of Canada to the United Nations to the Special Political and Decolonization Committee (Fourth Committee) Item 83: United Nations relief and works agency for Palestine refugees in the near east – November 3rd 2003. online at < http://www.dfait-maeci.gc.ca/Peaceprocess/Canadian_Statement_4th_Committee_Nov3-en.asp>

[22] Department of Foreign Affairs and International Trade, Canadian statement on the Middle East to the 59th Session of the United Nations Commission on Human Rights – 2003. online at < http://www.dfait-maeci.gc.ca/Peaceprocess/canada_statements_Middle_East_59th_Session-en.asp>.

[23] Department of Foreign Affairs and International Trade, Palestinian refugees: Report of the international mission to Lebanon – May 20-23, 1997- <http://www.dfait-maeci.gc.ca/Peaceprocess/lib_rap-en.asp#5>

[24] Supra note 17. 

[25] Immigration and Refugee Board, Interpretation of the Convention Refugee definition in the case law (Legal Services, December 31, 2002), at page 3-1.

[26] Ward, supra note 13.

[27] Ibid.

[28] Supra note 18.

[29] Adjei v. Canada (Minister of Employment and Immigration), [1989] 2 F.C. 680 (C.A.).

[30] Supra note 22.  

[31] Supra note 17; see also supra note 20.

[32] Supra note 31 at page 6-2; Ward, supra note 13.        

[33] El Khatib, Naif v. M.C.I. (F.C.T.D., no. IMM-5182-93), McKeown, September 27, 1994.

[34] Zakharia, L. Poverty Intensification Strategies: The Case of Palestinian Refugees”, FOFOGNET, Digest, 3 March 1997. 

[35] Department of Foreign Affairs and International Trade, Canada and the Middle East Peace Process, Canadian Policy (Key Issues). online at <http://www.dfait-maeci.gc.ca/Peaceprocess/keyissue-en.asp#occupied>.

[36] Ward, supra note 13.

[37] Rasaratnam v. Canada  (Minister of Employment and Immigration), [1992] 1F.C. 706 (C.A.)

[38] Thirunavukkarasu v. Canada (Minister of Employment and Immigration), [1994] 1 F.C. 589 (C.A.)

[39] Supra note 31 at page 8-1.

[40] Supra note 18.

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