Charkaoui, Re

Charkaoui, Re

Applying the IRPA and prior authorities, the Court held the applicable review standard approximates the preponderance threshold; it excluded the Zubaida statement from weight due to credible allegations of mistreatment but retained the Ressam identification; on the whole record the Ministers' evidence still established a serious danger and the applicant failed to discharge the shifted burden; no conceivable bail or conditions would neutralize that danger; continued detention ordered under s.83(3) IRPA.

Citation
2004 FC 1031
Parties
Ministers/respondents: Minister of Immigration and the Solicitor General of Canada; Detained Individual/applicant: Adil Charkaoui
Court
Federal Court
Jurisdiction
Canada
Judgment Date
23 July 2004
Procedural Posture
Detention Review Under the Immigration and Refugee Protection Act Arising From a Security Certificate Referral / Third Review of Detention; Motion to Continue Detention Under Subsection 83(3) IRPA
Outcome
Detention continued
Legal Topics
Security Certificate, Detention Review, Bail and Conditions, Standard of Proof, Exclusion of Evidence Obtained Under Torture, In Camera Proceedings
Source Language
English

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Parties

Minister of Immigration and the Solicitor General of Canada

Ministers/respondents

Adil Charkaoui

Detained Individual/applicant

Procedural Posture

Detention Review Under the Immigration and Refugee Protection Act Arising From a Security Certificate Referral / Third Review of Detention; Motion to Continue Detention Under Subsection 83(3) IRPA

  1. 1 Whether the respondent remains a danger to national security or to the safety of any person or is unlikely to appear at proceedings or for removal
  2. 2 Whether statements by Ressam and Zubaida should be excluded because obtained under torture or compulsion
  3. 3 What standard of proof applies on a detention review under section 83 IRPA

Ratio Decidendi

Applying the IRPA and prior authorities, the Court held the applicable review standard approximates the preponderance threshold; it excluded the Zubaida statement from weight due to credible allegations of mistreatment but retained the Ressam identification; on the whole record the Ministers' evidence still established a serious danger and the applicant failed to discharge the shifted burden; no conceivable bail or conditions would neutralize that danger; continued detention ordered under s.83(3) IRPA.

Court Disposition

Detention continued

Orders

  • Mr. Adil Charkaoui continue to be held in detention pursuant to subsection 83(3) of the Immigration and Refugee Protection Act until the designated judge rules anew on continuation of detention