TB8-10753

RAD File / Dossier de la SAR : TB8-10753 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person who is the subject of the appeal XXXX XXXX XXXX(a.k.a. XXXX XXXX XXXX XXXX Personne en cause Appeal considered / heard at Toronto, ON Appel instruit / entendu à Date of decision October 2, 2019 Date de la décision Panel G. Erauw Tribunal Counsel for the person who is the subject of the appeal Peter Lulic Conseil de la personne en cause Designated representative N/A Représentant(e) désigné(e) Counsel for the Minister N/A Conseil du ministre REASONS FOR DECISION OVERVIEW [1] XXXX XXXX (the "Appellant") is a citizen of China. The Appellant claims that the Public Security Bureau (PSB) is after her because she distributed leaflets on Christianity and attended an underground church in China. If she returns to China, she fears she will be arrested and tortured by the PSB for joining illegal religious activities and publicizing Christianity. [2] The Appellant appeals a decision of the Refugee Protection Division (RPD) rejecting her claim for refugee protection. She argues that the RPD erred in its credibility assessment by finding that a person cannot leave China with their own passport if they are wanted by the PSB, and that numerous country conditions documentation states there is no religious freedom in China and that persecution is on the increase. [3] For the reasons provided below, I find that the Appellant is not credible with respect to the PSB's interest in her because she was able to leave China on her own passport, and because the documentary evidence demonstrates that she does not face more than a mere possibility of persecution as a Christian if she returned to China. As a result, I confirm the RPD's decision that the Appellant is not a Convention refugee or a person in need of protection. This appeal is denied. ANALYSIS [4] As a preliminary issue, I note that the Appellant provides a written statement indicating that she does not rely on any new evidence in her appeal.1 She also makes no request elsewhere in her appeal record for the admission of new evidence and she makes no submissions in her memorandum for the admission of new evidence. However, the Appellant's memorandum cites documentary evidence that is not in the record, it does not appear in the RPD record or the appeal record. As a result, I am unable to consider the content of the documents cited. [5] Specifically, I note that the Appellant is not in compliance with the Refugee Appeal Division Rules.2 First, the Appellant has not provided copies of the documents she intends to rely on, and which she cites in her memorandum, but rather she has cut and pasted them into her submissions. The Refugee Appeal Division Rules require the Appellant to provide the documents she intends to rely on, which she has not done in this appeal.3 Furthermore, the Refugee Appeal Division Rules require the Appellant to explain how the documents submitted with her appeal record meet the requirements of section 110(4) of the Immigration and Refugee Protection Act.4 Without such an explanation for how the documents cited in her memorandum meet the requirements for new evidence, I am unable to determine if they meet the requirements of new evidence. For the above reasons, I am unable to consider the articles cited in her memorandum, as they have not been properly submitted or admitted as evidence. [6] Nevertheless, I observe that two of the documents cited by the Appellant in her memorandum do appear in the National Documentation Package (NDP) for China.5 As a result, I am able to consider the Appellant's arguments in relation to these documents, as they are in evidence. The Appellant is lacking in credibility that she is wanted by the PSB for her Christian activities [7] The RPD found that the Appellant lacked credibility with respect to her allegations that she is wanted by the Chinese authorities for distributing Christian leaflets in China. The RPD based its conclusion on the fact that the Appellant's ability to exit China on her own passport was inconsistent with the documentary evidence. [8] The Appellant argues that the RPD erred because it speculated that she would have to pass through many security checks, but did not give serious consideration to the fact that she said she used a smuggler and because Chinese officials are corrupt. In this case, she submits that the RPD's reliance on China's Golden Shield system means that any legitimate refugee claim would be rejected without reviewing the specifics of each case. [9] I agree with the Appellant that the RPD failed to fully explain why the Appellant's claims that she used a smuggler and that there is corruption in China did not account for her ability to exit China on her own passport and avoid the Golden Shield. However, based on my independent assessment of the evidence in the record, I find the Appellant's explanation that she was able to exit on her own passport because she used a smuggler and because there is corruption in China is not credible. The Appellant is not credible that she was able to exit China because of a smuggler [10] The Appellant testified that she was able to exit China because the smuggler took her to a room at the airport, where she was met by an unknown person. She then claimed that this person escorted her through an internal path, skipping security and customs. The Appellant stated that she was taken directly to the boarding area for her airplane. She claims that she travelled on her own passport and documents on the airplane that took her out of China. [11] With respect to the Appellant's submission that there is corruption in China, I am aware that there is evidence in the record demonstrating that there is widespread corruption in China. However, in my review of the documentary evidence there is insufficient objective evidence in the NDP, or in the Appellant's documents, which establishes that corruption extends to the airport security apparatus, particularly in the manner asserted by the Appellant.6 The objective evidence in the NDP makes no reference to persons being able to bribe airport security officials and bypass strict security measures with a smuggler as described by the Appellant. Rather the incidents mentioned in the NDP refer to persons travelling on false identities and documents, not on their own genuine passports, the latter of which is the Appellant's circumstance. [12] As correctly noted by the RPD, there is documentary evidence that indicates that corruption exists within the police force in China, and that authorities in China do not always apply regulations evenly, but the preponderance of the documentary evidence states that authorities at borders conduct thorough screenings.7 Moreover, even though the evidence states that corrupt practices are evident in many areas of Chinese society, in particular at the local level, most sources agree that corruption problems are concentrated in sectors with extensive state involvement, such as construction, land use, real estate, mining, and infrastructure development.8 [13] Also, recent corruption scandals have uncovered a number of cases where current and former government, Chinese Communist Party, security and state-owned enterprise officials have used forged and false identity and hukou documents, often with assistance from other state officials including police, to amass large property portfolios.9 I further observe, the current government has launched: an unprecedented anti-corruption campaign that has ensnared high-level leaders such as Bo Xilai and Zhou Yongkang, a campaign to encourage ideological orthodoxy in state agencies, universities, the media and the blogosphere, and a rule-of-law campaign emphasizing greater adherence to rules both inside and outside of the Party.10 I find that this is an indication that the Chinese government is monitoring government officials. [14] There is no corroboration for the Appellant's claim that individuals are able to circumvent airport security in the manner she alleges. I do not find the Appellant's explanation credible for how she exited the Guangzhou airport without presenting her passport to authorities. Given the many documents in the NDP about the security measures in place in Chinese airports and the Golden Shield, as well as the information about the scope of corruption in the country, I would expect the documentary evidence to mention whether corruption in airports can circumvent the Golden Shield.11 The Appellant also provides no evidence in her disclosure to support her assertion that she was able to avoid security screening at the airport because she used a smuggler and because there is corruption in China. The Appellant is not credible that the PSB is interested in her [15] Nevertheless, I note that even if the Appellant skipped security and customs inspection as she claims, and that she simply arrived at the boarding area, the documentary evidence still shows that her personal details would be shared with the Chinese authorities. In this case, the Appellant claims that she travelled on her own genuine passport to Canada and that she travelled by air to an unknown country after she left China. As a result, the Appellant would have possessed a boarding pass in her name in order to board her plane. The objective evidence indicates that airline officials would have shared her information with the authorities, as citizens can be tracked via airline passenger information. The documentation states that such passengers and their passport numbers are reported by the airlines to the authorities before passengers and crew go through the exit immigration procedures.12 [16] The Appellant's description of how she was able to exit China on her own genuine passport, despite the PSB's interest in her, is inconsistent with the documentary evidence. The documentary evidence convincingly shows that persons wanted by the PSB would be entered into an online database that is accessible by airport security officials. Officials at the airport would be alerted to wanted persons when their passports are scanned.13 A report in the NDP also states that "PSB investigations - including detention and arrest procedures - require 'meticulous documentation of offenders,' further noting that the PSB 'specifically requires documentation, reporting, and monitoring of potential offenders.'"14 In reviewing the exit procedure from China, I agree with the RPD that there is extensive information sharing between different law enforcement authorities,15 and that citizens can be tracked via airline passenger information.16 [17] Given the Appellant's description of exiting China using her own genuine passport and documents, and having a boarding pass in her own name, I find she would not have been able to do so if the PSB were interested in her as alleged. In this regard, the objective evidence states that officials at the airport would be alerted to wanted persons when their passports are scanned.17 Such passports are scanned when receiving their boarding pass, and at the immigration control.18 Furthermore, the Appellant's airline ticket, which includes her name is scanned at the boarding gate.19 The documents the Appellant claims to have travelled on in her own name would have been scanned, inspected and shared with officials at the airport, and I find she would not have been able to travel on these documents if the PSB were interested in her as she alleges. [18] I also reject the Appellant's argument that her exit was plausible because she was assisted by a smuggler who bribed authorities. I find it is not plausible that the Appellant's smuggler would have been able to bribe a host of PSB officials in relation to the passport, police working with the PSB according to the information sharing detailed in the NDP, and every possible passport control officer at the airport in order for her to have travelled safely through the airport without detection. [19] I find that the Appellant's allegation that she was able to exit China despite all the security measures in place because the smuggler helped her is not credible. For the above reasons, I also find the Appellant lacking in credibility in her allegation that the PSB is interested in her for Christian activities in China, and find that the PSB is not seeking her for distributing Christian leaflets. It is unlikely that a person wanted by the PSB would have been able to exit China on her own passport and with a boarding pass in her name. The Refugee Appeal Division (RAD) finds the Appellant does not face more than a mere possibility of persecution as a Christian in China [20] The Appellant argues that the RPD erred by finding she could return to China and practice Christianity in small groups/unregistered house church. She submits that the issue is whether there is freedom of religion in China when compared to Canadian or international law and that by forcing her to join a small house group to avoid arrest is unreasonable. The Appellant argues that she should be free to choose whatever church or group she wishes to join, and whether she can freely proclaim the church to others in private and public places. She does not have the option to join a large house church or evangelize openly anywhere in China. [21] I reject the Appellant's argument and find the RPD did not err. I find that the Appellant does not face more than a mere possibility of persecution as a practicing Christian in China. In coming to this conclusion, I emphasize the Appellant's profile as a practicing Christian. In particular, she states that the denomination of church is not important to her, as the only thing that is important to her is to believe in God. This is demonstrated by the fact that when she arrived in Canada she selected the church that was closest to her, despite alleging to belong to a different denomination in China. In addition, the Appellant provides no evidence that in order for her to truly practice her faith, she must proselytize Christianity publicly. In this respect, I highlight that I have found above that she is not credible in her allegation that she is wanted by the PSB for distributing Christian leaflets in China. Furthermore, there is no evidence the Appellant proselytized in Canada despite being free to do so. Rather, she stated that her religious practice in Canada included attending church, praying before bed, and volunteering at her church. Her support letter from the Living Stone Assembly in Canada makes no reference to the Appellant engaging in proselytizing or feeling required to proselytize her faith.20 The Appellant's profile is one of a woman who attended an underground church in Fujian province. She is not a pastor or leader, and she was not involved in a house church in China with foreign connections. It is in this context that the RPD and RAD assessed the Appellant's ability to return to China and freely practice her faith. [22] There is no determinative test that defines when interference with religious practices or proscription of one's religion amounts to persecution. However, the courts have provided some guidance. In Rajudeen, the Federal Court of Appeal found that persecution includes the element of "persistent or systematic infliction of harm"21 with respect to one's ability to practice his or her religion. The United Nations High Commissioner for Refugees (UNHCR) Handbook states that "[i]t is only in certain circumstances that discrimination will amount to persecution. This would be so if measures of discrimination lead to consequences of a substantially prejudicial nature for the person concerned, e.g. ... his right to practice his religion".22 The Supreme Court of Canada has also defined freedom of religion as referred to in the Canadian Charter of Rights and Freedoms to mean: "the right to entertain such religious beliefs as a person chooses, the right to declare religious beliefs openly and without fear of hindrance or reprisal, and the right to manifest religious belief by worship and practice or by teaching and dissemination".23 [23] The Appellant's ability to practice Christianity in China in Fujian province is determinative of the claim, given I found above that the Appellant is not credible in her allegation that she is wanted in China for distributing Christian materials. [24] The United States (US) Department of State's International Religious Freedom Report states: The constitution states citizens have "freedom of religious belief," but limits protections for religious practice to "normal religious activities." The constitution does not define "normal." The constitution provides for the right to hold or not hold a religious belief and states that state organs, public organizations, and individuals may not discriminate against citizens "who believe in, or do not believe in, any religion." The law does not allow for legal action to be taken against the government on the basis of the religious freedom protections afforded by the constitution. Criminal law allows the state to sentence government officials to up to two years in prison if they violate a citizen's religious freedom. There were no reported cases of such prosecutions during the year [2014]. ... Only religious groups belonging to one of the five state-sanctioned "patriotic religious associations" (Buddhist, Taoist, Muslim, Roman Catholic, and Protestant) are permitted to register with the government and legally hold worship services. Other religious groups, such as Protestant groups unaffiliated with the official patriotic religious association or Catholics professing loyalty to the Vatican, are not permitted to register as legal entities.24 [25] Despite the statement above that such unaffiliated Protestant groups are not permitted to register as legal entities, and therefore groups that do not register are technically illegal, the documentary evidence indicates there is uneven enforcement, with some churches meeting openly and regularly with large memberships. In fact, the documentary evidence confirms that the government is generally tolerant of groups that meet in homes or in small groups, but it is suspicious of religious organisations with foreign ties, memberships that grow quickly, whose leadership becomes too popular, or organizes across provincial lines, or whose religious activities disrupt ethnic or social harmony.25 Furthermore, the State Administration for Religious Affairs (SARA) in China has stated through a policy posted on its website that family and friends have the right to meet at home for worship, including prayer and Bible study, without registering with the government.26 [26] The documentary evidence also states that of the total population of China of 1.4 billion, there are between 200 and 657 million religious believers in the country.27 The estimated number of Protestant Christians is 68 million practitioners.28 The documentation also indicates that of practicing Protestants in China, more worship at unregistered churches than official churches.29 There are estimates that upwards of 70 million Christians practice without state sanction.30 Unregistered groups are not equated with groups that have been declared "evil cults", which face repression and are ruthlessly pursued, such as the "Local Church" or "Shouters".31 In some parts of the country, "unregistered groups have grown rapidly and the authorities do not pressure them to register" and "authorities tacitly approve of the activities of unregistered [church] groups and do not interfere with them".32 There are tens of thousands of unregistered churches in China, most of which carry out their business with little if any trouble from the local authorities.33 Many Christians in China are able to practise their faith in a lawful church and authorities do not generally concern themselves with small house church gatherings.34 This allows the Appellant to practice her faith in a manner consistent with her statement that what is most important is a belief in God, to attend church and pray, and to not have to worship at a patriotic church. [27] Furthermore, according to a United Kingdom (UK) Home Office report, Christianity is a fast-growing phenomenon in China, and notwithstanding a variety of official and social sanctions against it, the majority of Christians are able to worship and practice without facing serious difficulties. Millions of Chinese Christians manifest their beliefs openly, and senior government officials have praised religious communities' positive role in society, and urged approved religious groups to promote "economic and social development" and "socialist principles." [footnotes omitted]35 The document further states: [T]here has been a rapid growth in the number of Christians in China, both in the three State-registered churches and the unregistered or "house" churches. Individuals move freely between State-registered churches and the unregistered churches, according to their preferences as to worship.36 [28] In Fujian province specifically, I find that the preponderance of evidence indicates that Christians like the Appellant can practice their faith. I note that there is limited evidence in the documentation of incidents of persecution involving house church Christians in Fujian province. [29] The evidence about the practice of Christianity in Fujian province is that Fujian is much more "liberal" and even though some of the churches are not registered with the state, they operate quite openly.37 Item 12.5 of the NDP also highlights that Fujian is much more liberal than other areas of China.38 Moreover, item 12.13 of the NDP states that "Fujian is a province on the south-eastern coast of China, and is the province from which most asylum seekers have come to Australia. They have particularly come from the county of Fuqing City, which is part of the prefectural city of Fuzhou in the north of the province."39 This is the region of the province from which the Appellant originates. The background paper goes on to state that "both the province and the county contain relatively large numbers of Protestants, there are few reports of repression of house-church Christians in the province and the county."40 The Appellant attended a Protestant church in Canada, so she would be able to practice in a denomination she is most familiar. The estimate is that in 2004 there were nearly 1.2 million Protestants in Fujian, with at least 350,000 in the Fuzhou area.41 According to the background paper, "the official religious policy has been applied relatively liberally in Fujian, although there have been occasional crackdowns on house churches and 'underground' Catholics."42 [30] A 2009 report on the Protestant Church in Fujian province confirms that there are large numbers of independent house churches in Fujian. The report also indicates that "[i]n general, local government in Fujian seems fairly tolerant of unregistered believers as it is rare that one reads of cases of persecution of house-church Christians in this province."43 Fujian is rarely mentioned in reports on breaches of religious freedom by the US Department of State, the United States Commission on International Religious Freedom, Amnesty International, Human Rights Watch or the various Christian NGOs that report on China. Nevertheless, the background paper in the NDP summarized all the incidents reported since 2006 at the time of its publication in March 2013: * In December 2012, Fujian was mentioned in relation to a nationwide crackdown on members of a Christian sect, the so-called Church of Almighty God, also known as Eastern Lightning. This well-known sect declared as an "evil cult" and has been condemned by other Christian groups. * In October 2010, the authorities reportedly took away a worker and sealed three venues used for church gatherings of a church in Lianjiang county in Fujian, which was described as having a strong heart for "evangelism". * Two localities in Fujian province reported that public security forces targeted the "Local Church", which is a banned Protestant group that officials refer to as the "Shouters". * In 2006, police closed unregistered places of worship in various provinces including Fujian, according to the US Department of State. The 2006 annual report of the China Aid Association also reports on the demolition of house churches in Jilin and Fujian. The report cites an incidence in September 2006 in which a house church was destroyed in Pingtan County, Fujian. A September 2006 report from Asia News provides more detailed information on the demolition of the unofficial church in Pingtan County.44 [31] Although the above incidents are unfortunate, a couple of them involve clearly banned groups identified as "evil cults" and/or evangelical, of which the Appellant is not a member, nor has she expressed or demonstrated a proclivity for evangelism. Furthermore, there were few details provided regarding the reasons for the demolition(s) in Fujian or where they occurred within the province. Moreover, they occurred 13 years ago. I find that this vague and dated information is insufficient to indicate that Christians are unable to worship in house churches in Fujian province, where the Appellant originates. [32] Finally, the UK Home Office Report stated that in general the treatment faced by Christians in China, including those from unregistered churches, is unlikely to amount to persecution: Caselaw from early 2014 established that in general, the risk of persecution for Christians expressing and living their faith in China is very low. There may be a risk of persecution or serious harm for dissident bishops or certain individual Christians who choose to worship in unregistered churches and who conduct themselves in such a way as to attract the local authorities' attention to them or their political, social or cultural views. [emphasis added]45 This is not a profile the Appellant shares. While I acknowledge that the documentary evidence concerning the treatment of house Christians is mixed and that there are examples of authorities harassing congregants, this often does not rise to the level of persecution. The UK Home Office notes that members of unregistered Protestant groups that the government identifies as evil cults appear to be the most vulnerable to detention, arrest and harassment.46 [33] Based on the above review of the documentary evidence, I find there is insufficient evidence to establish that Christians are unable to worship in house churches in Fujian province. There is no information in the documentary evidence that any worshipers of underground Protestant house churches were arrested for practicing Christianity in Fujian province or that the police conducted raids on small house churches. I have also considered the Appellant's risk of persecution in light of the number of Christians practicing in China in unregistered churches and find it less than a mere possibility, not more than a mere possibility. I have assessed the documentary evidence about the conditions in Fujian province and the Appellant's personal circumstances, in particular the fact that the denomination of her faith is not important to her. I find there is insufficient evidence to conclude that the Appellant would face persistent, serious and systemic harm by practicing Christianity in a house church in Fujian province. Therefore, I find on a balance of probabilities that the Appellant would be able to practice Christianity and worship in the Christian congregation of her choosing, if she were to return to Fujian province in China. CONCLUSION [34] After conducting its own analysis of the entire record, the RAD finds that the RPD did not err in its credibility finding that the Appellant is not wanted by the PSB for her Christian activities in China. Moreover, in my independent assessment of the documentary evidence I concur with the RPD that even though the Appellant is a Christian, she does not face more than a mere possibility of persecution if she returned to China. As a result, I find the RPD's determination that the Appellant is not a Convention refugee or a person in need of protection is correct, and this appeal is dismissed. DETERMINATION [35] The RAD dismisses the appeal and confirms the decision of the RPD that the Appellant is neither a Convention refugee nor a person in need of protection, pursuant to section 111(1)(a) of the Immigration and Refugee Protection Act. (signed) "G. Erauw" G. Erauw October 2, 2019 Date 1 Exhibit P-2, Appellant's Record, Appellant's Written Statement, at p. 13. 2 Refugee Appeal Division Rules, SOR 2012/257. 3 Refugee Appeal Division Rules, SOR 2012/257, at r. 3(3)(e) and r. 31(1). 4 Refugee Appeal Division Rules, SOR 2012/257, at r. 3(3)(g)(iii); and see Ilias v. Canada (Citizenship and Immigration), 2018 FC 661, at para. 33. 5 Exhibit P-2, Appellant's Record, Appellant's Memorandum, at pp. 55-59; Exhibit RPD-1, RPD Record, Exhibit 3, National Documentation Package (NDP) for China (31 October 2017), items 12.1 and 12.5. 6 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 16.3, at pp. 7-8; items 14.3, 14.8, 14.11, and 14.15. 7 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), items 14.3, 14.8, 14.11, and 14.15. 8 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.7, at pp. 4, 6, 15, 41, and 44; item 2.1, at pp. 47-48; item 2.3, at p. 172; item 2.12, at pp. 17-18, 121, 148, and 152; item 2.7, at p. 10; item 7.1, at pp. 2-3. 9 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 3.22. 10 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 4.8. 11 Adu v. Canada (Minister of Employment & Immigration), [1995] F.C.J. No. 114 (FCA), at para. 1. 12 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 14.15. 13 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 14.3. 14 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 12.8, at p. 2. 15 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 14.3. 16 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 14.8. 17 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 14.3. 18 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 16.3, at p. 4. 19 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), at item 16.3, at p. 4. 20 Exhibit RPD-1, RPD Record, Exhibit 7, Support Letter of Living Stone Assembly, at p. 117. 21 Rajudeen v. Canada (Minister of Employment and Immigration) (1984), 55 N.R. 129 (F.C.A.). 22 United Nations High Commissioner for Refugees, Handbook and Guidelines on Procedures and Criteria for Determining Refugee Status under the 1951 Convention and the 1967 Protocol relating to the Status of Refugees, Reissued, Geneva, December 2011, <http://www.refworld.org/docid/4f33c8d92.html>, at p. 14, para. 54. 23 Syndicat Northcrest v. Amselem, [2004] 2 SCR 551, 2004 SCC 47, at para. 40. 24 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at pp. 9-10, s. 5.1.1, see also p. 4, s. 2.2.3. 25 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 2.12, at pp. 194 and 199. See also item 12.6, at pp. 3-4. 26 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at s. 5.1.2. 27 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.1, at p. 3. 28 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.1, at p. 3. 29 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 3. 30 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 4. 31 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at pp. 2, 7. 32 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at pp. 8, 18. 33 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 16. 34 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13. 35 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at s. 4.1.1. 36 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at s. 2.2.2. 37 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 21. 38 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.5, at p. 25. 39 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 21. 40 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 21. 41 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 21. 42 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 21. 43 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at p. 22. 44 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 12.13, at pp. 22-23. 45 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at ss. 3.1.1-3.1.2. 46 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for China (31 October 2017), item 1.8, at s. 4.1.5. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD File / Dossier de la SAR : TB8-10753 RAD.25.02 (April 04, 2019) Disponible en français 15 Immigration and Refugee Board of Canada Refugee Appeal Division Commission de l'immigration et du statut de réfugié du Canada Section d'appel des réfugiés RAD.25.02 (April 04, 2019) Disponible en français