Jean-Pierre v. Canada (Immigration, Refugees and Citizenship)

Jean-Pierre v. Canada (Immigration, Refugees and Citizenship)

The motion for recusal was dismissed because a reasonable and well-informed person, applying the test from R. v. S. (R.D.), would conclude that the applicant's disagreement with prior tribunal and judicial review decisions and his conclusions do not establish a reasonable apprehension of bias; the presumption of...

Source-derived case information.

Citation
2017 FCA 200
Parties
Applicant: Gandhi Jean-Pierre; Respondent: The Chairperson of the Immigration and Refugee Board of Canada
Court
Federal Court of Appeal
Jurisdiction
Canada
Judgment Date
26 September 2017
Procedural Posture
Judicial Review — Motion for Recusal / Decision on Motion (recusal)
Outcome
Motion for recusal dismissed.
Legal Topics
Recusal, Reasonable Apprehension of Bias, Judicial Impartiality, Unanimous Panel
Source Language
en
Immigration Law Administrative Law Tribunal Review Judicial Review Recusal Reasonable Apprehension of Bias Judicial Impartiality Unanimous Panel

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Parties

Gandhi Jean-Pierre

Applicant

The Chairperson of the Immigration and Refugee Board of Canada

Respondent

Procedural Posture

Judicial Review — Motion for Recusal / Decision on Motion (recusal)

  1. 1 Whether the judge(s) should be recused for reasonable apprehension of bias
  2. 2 Whether disagreement with prior tribunal and judicial review decisions establishes bias
  3. 3 Applicability of the presumption of judicial impartiality to a unanimous court of appeal panel

Ratio Decidendi

The motion for recusal was dismissed because a reasonable and well-informed person, applying the test from R. v. S. (R.D.), would conclude that the applicant's disagreement with prior tribunal and judicial review decisions and his conclusions do not establish a reasonable apprehension of bias; the presumption of impartiality, heightened for a unanimous panel, remains intact.

Court Disposition

Motion for recusal dismissed.

Orders

  • Motion for recusal dismissed.