TB6-18943

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 File No. / N° de dossier de la SAR : TB6-18943 TB6-18944 TB6-18945 TB6-18946 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person(s) who is(are) the subject of the appeal XXXX XXXX XXXX XXXXXXXXXXXX XXXX XXXXXXXXXXXX XXXX XXXXXXXXXXXX XXXX Personne(s) en cause Appeal considered / heard at Toronto, Ontario Appel instruit à Date of decision June 15, 2017 Date de la décision Panel Lesley Mason Tribunal Counsel for the person(s) who is(are)the subject of the appeal Orr Kolesnik Conseil(s) du (de la/des) personne(s) en cause Designated Representative(s) N/A Représentant(e)(s) désigné(e)(s) Counsel for the Minister N/A Conseil du ministre REASONS FOR DECISION [1] XXXX XXXX XXXX (the Appellant), her son, XXXX XXXX and daughters, XXXX XXXX XXXX XXXX XXXX (the minor Appellants) are appealing the decision of the Refugee Protection Division (RPD) denying their claims for refugee protection. The Appellant and two of the minor Appellants, XXXX and XXXX XXXX, are citizens of Nigeria. XXXX XXXX is a citizen of Nigeria and of the United States (US). The Appellant is requesting that the Refugee Appeal Division (RAD) set aside and substitute the negative determination with a positive determination or in the alternative, that the matter be referred back to a different member of the RPD for re-determination. The Appellant submits no new evidence nor does she request an oral hearing under section 110(6) of the Immigration and Refugee Protection Act (IRPA). DETERMINATION [2] Pursuant to section 111(1)(a) of the IRPA, the RAD confirms the determination of the RPD that the Appellants are not Convention refugees nor are they persons in need of protection. The RAD dismisses the appeal. Background [3] The Appellant alleges that when she married her husband, XXXX XXXX in 2005, her husband's uncle, XXXX XXXX XXXX XXXX XXXX was against their marriage. The Appellant learned that in her husband's culture a female child is usually betrothed to the son of another family. XXXX believed the Appellant was too old to marry her husband. The marriage produced three children, the minor Appellants. [4] The Appellant's husband was successful financially such that the Appellant did not have to work. The Appellants and the Appellant's husband spent holidays in the US and the United Kingdom. In 2016 they applied for and were granted visitors' visas to Canada. Their trip to Canada, scheduled for XXXX XXXX, 2016, was postponed because the Appellant's husband was summoned to his village at the time they were to leave. At the village the Appellant's husband was informed that XXXX, the older female minor Appellant, had been betrothed since birth to the son of the XXXX family. The son was now a university student. When the Appellant's husband informed her of the planned marriage, the Appellant told her husband that she refused to have her daughter married. [5] On XXXX XXXX, 2016, XXXX attended the Appellants' home and advised the Appellant that the marriage would take place in XXXX, 2016. [6] The Appellant and her husband decided that they would continue with their vacation plans to Canada. They arrived in Canada on XXXX XXXX, 2016. [7] After having arrived in Canada, the Appellant learned XXXX XXXX had again attended her parents' home and threatened to deal with her parents if they did not produce XXXX. [8] The Appellant informed a friend whom she had met at a mosque in Canada of her problems in Nigeria. The friend introduced the Appellant to a lawyer who advised her of her options. The Appellants made sur place claims for refugee protection on September 27, 2016. [9] The Appellants had a refugee determination hearing on November 21, 2016. In a written decision issued on November 25, 2016, the RPD rejected the claims. The RPD rejected the claim of XXXX XXXX because she has no fear of persecution in the US. The RPD rejected the claim of XXXX XXXX, the minor male claimant, because he had no fear of persecution in Nigeria. The RPD found that the Appellant was not credible and, thus, rejected the claims of the Appellant and the remaining minor female Appellant, XXXX XXXX. [10] Appeal pleadings were received on January 13, 2017. The Appellant submits that the RPD erred in its credibility findings. ROLE OF THE RAD [11] The RAD finds that the recent Federal Court of Appeal decision, in Huruglica,1 provides the RAD with guidance in relation to the appropriate standard that must be applied by a specialized tribunal such as the RAD to decisions of a first-level administrative tribunal. [103] I conclude from my statutory analysis that with respect to findings of fact (and mixed fact and law) such as the one involved here, which raised no issue of credibility of oral evidence, the RAD is to review RPD decisions applying the correctness standard. Thus, after carefully considering the RPD decision, the RAD carries out its own analysis of the record to determine whether, as submitted by the appellant, the RPD erred. Having done this, the RAD is to provide a final determination, either by confirming the RPD decision or setting it aside and substituting its own determination of the merits of the refugee claim. It is only when the RAD is of the opinion that it cannot provide such a final determination without hearing the oral evidence presented to the RPD that the matter can be referred back to the RPD for redetermination. No other interpretation of the relevant statutory provisions is reasonable. ANALYSIS OF THE EVIDENCE [12] The RPD found that the minor Appellant, XXXX XXXX XXXX XXXX XXXX was not a Convention refugee nor a person in need of protection. The RPD based this finding upon the fact that XXXX is a citizen of the United States by birth and that the Appellant had testified that XXXX had no claim against the United States and XXXX had no fear of persecution in the United States. [13] The Appellant makes no submissions on this finding. [14] The RAD agrees with the RPD's finding. [15] The RPD found that the male minor Appellant, XXXX XXXX XXXX XXXX XXXX was not a Convention refugee nor a person in need of protection. The RPD based its finding on the Appellant's testimony that XXXX does not have fear of persecution at the hands of the agent of persecution and XXXX came to Canada with his family because he could not be left behind while the family travelled on holidays. [16] The Appellant made no submissions on this finding. [17] The RAD, thus, agrees with this finding. The RAD notes that according to the recording of the hearing, the Appellant's counsel confirmed this finding. Credibility [18] The RPD found that it was not persuaded that an individual named XXXX XXXX is the uncle of her husband living in Nigeria as an XXXX XXXX or an XXXX. The RPD concluded by finding that it was, therefore, implausible that XXXX XXXX has any interest to harm the Appellants. The RPD based its findings on the lack of documentary evidence. The RPD noted that the Appellant failed to provide the following documents: * Photo-identity XXXX XXXX; * Documents to connect XXXX to the Appellant's husband; * Death certificates of her husband's parents or school documents of her husband to indicate that he had been raised by XXXX as a result of the death of his parents; * Documents to show XXXX XXXX and/or her husband are from northern parts of Nigeria and members of the Hausa tribe; * Documents regarding XXXX position as a XXXX and an XXXX; * Document, such as a notarized affidavit, from her husband to provide evidence regarding XXXX. [19] The Appellant submits that the RPD erred in mixed law and fact in expecting her to provide identity documents of her agent of persecution. The Appellant submits that most of the documents required by the RPD were not available to her. She submits that she could not have approached the agent of persecution for many of the documents requested by the RPD. The Appellant submits that the RPD erred in assuming that if XXXX was a businessman that his profile would easily be available on the internet. The Appellant submits that documentary evidence indicates that the internet is limited in Nigeria and, in addition, XXXX is not very technologically savvy. The Appellant submits that the RPD erred by not giving much weight to the affidavit that her husband provided for her hearing. The Appellant further submits that the RPD erred in determining her not credible based only on the lack of supporting documents. The Appellant depends upon the jurisprudence in this particular submission.2 [20] The RAD acknowledges the deference it should show to the RPD's finding but nonetheless finds it cannot recognize and respect it. For the following reasons, the RAD finds that the Appellant's submissions have merit. [21] The RAD agrees that the RPD's reliance on the lack of documentary evidence for its credibility findings is flawed. The RPD in its reasons found no inconsistencies in the Appellant's testimony when compared to information the Appellant provided in her Basis of Claim (BOC) form. The RPD may reasonably draw an adverse credibility inference from an Appellant's failure to present evidence supporting her claim if the account consists of a lack of credibility on key issues, stemming from clear inconsistencies and implausibilities in oral testimony. The RAD is guided by the jurisprudence for the proposition that the RPD is entitled to draw a negative inference from an Appellant's failure to provide corroborating evidence when there are inconsistencies in the claimant's testimony.3 In addition, Justice Martineau held in Morka that in certain circumstances, where the claimant's account lacks credibility on key issues, it is reasonable to ground an adverse credibility finding on an absence of documentation to support an applicant's allegations.4 The Appellant's documentary evidence [22] The RPD found that the affidavit from the Appellant's mother5 and police report consisting of a complaint made to the police by the Appellant's mother6 were fraudulent and fabricated to bolster the Appellant's claim. The RPD based its finding on the discrepancies between information provided by the mother in the affidavit and in the complaint to the police. In the affidavit the mother affirms XXXX XXXX visited her home on XXXX XXXX, 2016 in the company of two women while the complaint to the police make no mention XXXX XXXX attending the mother's home on that date. The RPD found that the Appellant did not provide a reasonable explanation for the discrepancies. [23] The Appellant submits that due to punctuation or grammatical-clerical error, the entire statement in the police report "XXXX XXXX XXXX whose house address is XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX XXXX came to my house XXXX XXXX, 2016..."7 could have been misinterpreted by the RPD. The Appellant submits that the statement indicates XXXX XXXX went to her house and also sent two women. [24] The RAD is not persuaded by the Appellant's submissions. [25] The RAD appreciates that there is a confusion with the use of the verb "came" in the sentence under discussion. However, two sentences later, the following information is provided in the police report: On XXXX XXXX, 2016, XXXX XXXX, came accompanied by the two women that came previously, to my house...8 [emphasis added] [26] The RAD finds that this sentence clarifies the information in the sentence referred to the Appellant, that only the two women attended the house of the Appellant's mother on XXXX XXXX, 2016. [27] The RAD, thus, gives little evidentiary weight to these two documents. The RAD also finds that where there is no reasonable explanation for a material contradiction in the Appellant's documentary evidence, it can be the basis of an adverse inference and impugn the Appellant's credibility. The Appellant's testimony [28] Regardless of the RPD's making no credibility findings regarding the Appellant's testimony, the RAD finds that information gathered during the hearing before the RPD is insufficient for the RAD to make its own credibility findings. The RAD is, therefore, unable to make any finding on the overall credibility of the Appellant. The RAD's reasons follow. [29] According to the recording of the one and a half hour hearing, the majority of the hearing was spent on questioning the Appellant about the lack of documentary evidence. The RAD finds that the RPD questioned the Appellant very little about the basis of her claim. When the RPD did question the Appellant about the basis of her claim, there were instances where the RPD provided the Appellant with information contained in her written narrative and then asked the Appellant to confirm the information. For example, the RPD asked the Appellant why she feared returning to Nigeria. She testified that she did not wish to have her eight year old daughter married. When asked why she could not return to Nigeria without her daughter, the Appellant testified XXXX XXXX would hunt her down. The RPD then referred to the Appellant's BOC and asked the Appellant why XXXX had attended her mother's home. A little later in the hearing, the RPD again referred to information in the Appellant's BOC which states that XXXX visited her mother's home after the Appellant arrived in Canada. The Appellant responded in the affirmative. When the RPD repeated the information, the Appellant again responded in the affirmative. The RPD then asked the Appellant to confirm XXXX XXXX had visited her mother's home on two occasions, which she did. [30] Regardless of the one credibility concern regarding documentary evidence provided by the Appellant, outlined above, the RAD finds that the determinative issue is the viability of an internal flight alternative. The Appellant was invited to provide written submissions to the RAD on this issue. The RAD has considered the Appellant's submissions which were received by the RAD on May 29, 2017.9 Internal flight alternative (IFA) [31] After a review of the complete record, including a recording of the hearing and the Appellant's written submissions, the RAD finds there was evidence before the RPD of the existence of the determinative issue of an accessible and reasonable internal flight alternative. [32] For the reasons that follow, the RAD can confirm the RPD's determination by making its own findings on the issue of an IFA. [33] The RAD focused on whether the Appellants have an accessible and viable IFA in Abuja, Benin City or Enugu. [34] In order to determine whether a viable IFA exists, the RAD must consider a two-pronged test. The basis for this two-pronged test is the cases of Rasaratnam10 and Thirunavukkarasu.11 [35] Firstly, the Board must be satisfied, on a balance of probabilities, that there is no serious possibility of the Appellants being persecuted in the part of the country to which it finds an IFA exists.12 [36] Secondly, conditions in that part of the country considered to be an IFA must be such that it would not be unreasonable, in all circumstances, including those particular to the claimant, for him or her to seek refuge there.13 [37] The Appellant bears the burden of proof to show that she faces a serious possibility or reasonable chance of persecution in the entire country and specifically in the potential IFA areas named. [38] The RAD finds, on a balance of probabilities, there is no serious possibility that the Appellants would be persecuted in Nigeria if they were to relocate to Abuja, Benin City or Enugu, Nigeria. The RAD's reasons are as follows. The first prong of the IFA [39] According to the recording of the hearing, when the Appellant was asked whom she feared if she were to return to Nigeria, she testified that she feared her husband's uncle, XXXX. [40] According to information contained in an affidavit provided by the Appellant's mother, XXXX visited her home on XXXX XXXX, 2016 in the company of two women.14 The mother affirms XXXX XXXX threatened to burn down her home if she did not advise the Appellant to return with her daughter, XXXX. A police report indicates that XXXX sent two women to the home of the Appellant's mother on XXXX XXXX, 2016 and on XXXX XXXX, 2016 he accompanied the same two women to the home of the Appellant's mother.15 Apparently, XXXX physically abused the Appellant's mother in an attempt to learn the whereabouts of the Appellant and XXXX and he threatened further physical abuse. However, the mother provided XXXX with no information. [41] According to the recording of the hearing, the Appellant testified that her husband grew up under the care XXXX XXXX. She testified XXXX XXXX is an imam and a XXXX contractor. She testified that he is a member of the Hausa tribe and resides in her husband's home village in northern Nigeria. When asked about relocating to other cities in Nigeria, the Appellant testified that the XXXX people are everywhere and that all XXXX needs to do is speak to his Hausa people. In written submissions, the Appellant submits XXXX XXXX is a man of power all over Nigeria due to his being an imam and his influence among the Muslim community. [42] The RAD finds that there is no persuasive evidence, other than the Appellant's testimony and her written submissions, XXXX XXXX is highly placed or influential throughout Nigeria or among the Muslim community. According to documentary evidence, the Hausa-Fulani people make up 29% of the Nigerian population or approximately 60 million people16 and 50% of the Nigerian population is Muslim17 which is approximately 90 million people. The Appellant has provided no persuasive evidence that XXXX is highly place or influential among the numerous Hausa people or vast number of Muslims. The RAD reasonably expects that if the XXXX were a man of such influence throughout Nigeria that documentary evidence would be available. In any case, the documentary evidence indicates that the Hausa ethnic group live predominantly in Muslim northern states.18 None of the proposed IFA locales are in the northern state. The Appellant did not allege either through oral testimony or documentary evidence XXXX XXXX or those under his direction are searching for the Appellants throughout Nigeria or that they have the will or capacity to do so. [43] Nigeria is a large country with a population of over 180 million, covering an area of over 900,000 square kilometres in 36 states.19 A report from the United Kingdom (UK) Home Office states that Nigerians can freely travel within Nigeria.20 The same report states that the 1999 Nigerian constitution provides for the freedom of movement within Nigeria, and states that every citizen of Nigeria is entitled to move freely throughout Nigeria and to reside in any part thereof, and no citizen of Nigeria shall be expelled from Nigeria or refused entry thereto or exit therefrom.21 There are international airports in both Abuja and Enugu; Benin City is approximately 250 kilometres from Enugu.22 Therefore, it would be unnecessary for the Appellants, upon returning to Nigeria, to travel through XXXX where they resided and where XXXX searched for them on two occasions. If the Appellant does not wish to inform others of their presence in any of the IFAs, there is no reason to believe that their location would be found out. [44] The IFAs are very large cities. Abuja has a population of over 2.4 million, Benin City 1.5 million, and Enugu approximately 700, 000.23 The RAD has considered that the Appellants are members of the Yoruba tribe and her husband a member of the Hausa tribe. According to a Response to Information Request (RIR),24 being an indigene (of ethnic majority status) is less important in big cities than it is in other places because the indigene population in these areas has been "overwhelmed" by migrants to the cities. [45] The Appellants have been out of Nigeria for approximately nine months. There is no persuasive evidence that there is a large resourceful group of people in Nigeria that continue to search for the Appellants or would seek them out in all parts of a country of over 180 million people. [46] Thus, the RAD finds that the Appellant has failed to provide a reasonable explanation as to why she believes the Appellants would be discovered and/or harmed in any of the IFAs. [47] The RAD finds, on the basis of the evidence before it, that the Appellant has not established, on a balance of probabilities, that the Appellants would be tracked down or targeted in Abuja, Benin City or Enugu. Given the lack of evidence presented related to the influence and reach of the agent of persecution, XXXX, the RAD finds that the Appellant has not adduced sufficient evidence to establish, on a balance of probabilities, that there is a serious possibility of being persecuted in the IFA cities or that the Appellants would be personally subjected to a risk to life or a risk of cruel and unusual treatment or punishment or a danger, believed on substantial grounds to exist, of torture in Abuja, Benin City or Enugu. The second prong of the IFA [48] With respect to the second prong, the RAD is not persuaded that it would be unreasonable for the Appellant to live in Abuja, Benin City or Enugu. [49] In written submissions, the Appellant argues that the RAD must consider factors such as the composition of her family unit, her ability to raise a family, their religion, and her political profile. Other than the Appellant's political profile, the RAD has considered these factors. The Appellant has provided no explanation nor evidence regarding her political profile. [50] According to information contained in the Appellant's BOC form25 and provided in her oral testimony, the Appellant's husband supports her against his uncle XXXX demands for their eldest daughter's marriage. The RAD notes that the Appellant's husband provided an affidavit for the Appellant's hearing in which he provides similar information.26 The Appellant made no allegations that her husband would not support her or her children upon their return to Nigeria or that he would not reside with them in any of the IFA locales. The RAD, therefore, reasonably assumes that the Appellant's husband could reside with the Appellant s in the IFA locales. [51] The Appellant has provided no persuasive evidence that the Appellants could not adapt to the cultural issues and norms in these cities. According to information contained in the Appellant's BOC form, the Appellants have travelled internationally on more than one occasion prior to coming to Canada.27 The Appellant gave birth to her youngest child in the US.28 The Appellant has thus shown that she is capable of handling international travel and new environments. The RAD notes that the Appellants have settled in Toronto. Therefore, the RAD is satisfied that it would be reasonable for the Appellants to adapt to new surroundings in Abuja, Benin City or Enugu. The RAD understands that there would be a period of adjustment in any of the recommended IFA cities but the RAD has been provided with insufficient evidence that the effect of relocation would result in great danger and that the Appellants would undergo undue hardship either in travelling or remaining there. The RAD finds it reasonable that the Appellant would be familiar with religious practices in the IFA locales. The Appellant is Muslim.29 According to the recording of the hearing, the Appellant testified that her husband and children are Muslims. The documentary evidence states that there are about equal numbers of Christians and Muslims in the areas of the proposed IFA cities.30 The RAD notes that the Appellant previously resided in XXXX which has a similar religious demographic. [52] The Appellant testified in the English language and states in her BOC form she speaks both English and Yoruba.31 According to the recording of the hearing, when asked about relocating within Nigeria, the Appellant testified that she does not speak Hausa. The RAD is not proposing that the Appellant relocate to northern Nigeria, the area of Nigeria where Hausa is the main language. In any event, English is the official language of Nigeria.32 As stated earlier, the cities proposed as IFA locales are all large cities. The RAD has previously referred to information provided in an RIR33 that being an indigene is less important in big cities than it is in other places because the indigene population in these areas has been "overwhelmed" by migrants to the cities. The RAD is, therefore, satisfied that the Appellants would be familiar with the language and religion in Abuja, Benin City, and Enugu. [53] The documentary evidence also states that people mainly rely on immediate or extended family in a time of crisis. The Appellant's husband, mother, and friend in XXXX each provided documents to support the Appellant's claim.34 The Appellant provided no persuasive evidence that she could not continue to receive support from her immediate family members and her friend. As stated above, the RAD has no reason to doubt that her husband would relocate with her and their children to the IFA locale. [54] The RAD has also considered economic concerns for the Appellant and her children. According to an RIR found in the independent documentary evidence, the survival of a family headed by a woman relies on a woman's socio-economic status.35 The same RIR states that the Women's Rights Watch Nigeria project coordinator stated that if women are educated, it is "easier to cope" with running a household without male or family support. [55] The RAD considered the Appellant's current profile in Nigeria and although the RAD has considered that the Appellant's husband would reside with the family, the RAD finds that the Appellant would be capable of heading the household on her own. According to information the Appellant provided at the port of entry (POE), she obtained a Bachelor's Degree from the University XXXX XXXX XXXX Her education is well beyond the average number of years of formal education completed by females which the independent documentary evidence indicates is nine years.36 In written submissions, the Appellant submits that her husband would have to cut all ties with his relatives and with his employment activities if he relocates to any of the IFA cities. The RAD appreciates that a relocation for the husband might require new employment. As indicated above, the Appellant stated in her BOC narrative that her husband was financially successful in his business. There is no persuasive evidence to suggest that the Appellant would be at a greater disadvantage in Abuja, Benin City or Enugu of finding employment than any other Nigerian woman with her education, nor would her husband. Based upon the Appellant's age, education, and language capability stated earlier and the support of her husband, the RAD finds there are no serious social or economic barriers to the Appellants relocating to one of the IFA locales. The RAD reasonably assumes that the husband has maintained contact with family members who support him against XXXX and, thus, would not require his cutting contact with such family members. In any event, the husband could chose to keep in contact with those whom he trusts. [56] Therefore, the RAD finds that it would not be unreasonable, in all circumstances, including those particular to the Appellants, for them to seek refuge in Abuja, Benin City or Enugu. Summary [57] The RAD finds that the Appellants have a viable internal flight alternative in Nigeria. DISPOSITION [58] Based on the analysis above, the RAD confirms the determination of the RPD that the Appellants are not Convention refugees nor are they persons in need of protection, as per section 111(1)(a) of the IRPA. [59] The appeal is dismissed. (signed) "Lesley Mason" Lesley Mason June 15, 2017 Date 1 M.C.I. v. Huruglica, Bujar (F.C.A., no. A-470-14), Gauthier, Webb, Near, March 29, 2016, 2016 FCA 93. 2 X(Re), 2014 CanLII 95936 (CA IRB). 3 Vasquez Encinas, Migual Nagel v. M.C.I. (F.C., no. IMM-4548-05), Noël, January 23, 2006, 2006 FC 61; Villeda Mejia, Selvin Manrique v. M.C.I. (F.C., no. IMM-356-09), Pinard, October 29, 2009, 2009 FC 1091. 4 Morka, Maria Obianuju v. M.C.I. (F.C., no. IMM-4120-06), Martineau, March 26, 2007, 2007 FC 315. 5 Exhibit RPD-1, RPD's Record, p. 243. 6 Ibid., pp. 241-242. 7 Exhibit RPD-1, RPD's Record, p. 241. 8 Ibid. 9 Exhibit P-3, Appellant's Written Submissions. 10 Rasaratnam, Sivaganthan v. M.E.I. (F.C.A., no. A-232-91), Mahoney, Stone, Linden, December 5, 1991. Reported: Rasaratnam v. Canada (Minister of Employment and Immigration), [1992] 1 F.C. 706 (C.A.), at 710. 11 Thirunavukkarasu, Sathiyanathan v. M.E.I. (F.C.A., no. A-81-92), Heald, Linden, Holland, November 10, 1993. Reported: Thirunavukkarasu v. Canada (Minister of Employment and Immigration), [1994] 1 F.C. 589 (C.A.); (1993), 22 Imm. L.R. (2d) 241 (F.C.A.). 12 Rasaratnam, supra, footnote 10. 13 Thirunavukkarasu, supra, footnote 11. 14 Exhibit RPD-1, RPD's Record, p. 243. 15 Exhibit RPD-1, RPD's Record, pp. 241-242. 16 Exhibit RPD-1, RPD's Record, National Documentation Package (NDP) for Nigeria (April 29, 2016), item 1.6. 17 Ibid., item 12.1, p. 2, section I. 18 Ibid., item 1.6. 19 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 1.6. 20 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 1.7, section 1.2.8. 21 Ibid., item 1.7, section 2.8.1. 22 Exhibit RPD-1, RPD Record, NDP for Nigeria (April 29, 2016), item 1.1. 23 Ibid., item 1.6. 24 Ibid., item 13.1, p. 9. 25 Exhibit RPD-1, RPD's Record, pp. 10-51. 26 Exhibit RPD-1, RPD's Record, p. 240. 27 Exhibit RPD-1, RPD's Record, pp. 10-20, BOC form. 28 Exhibit RPD-1, RPD Record, p. 237. 29 Exhibit RPD-1, RPD's Record, p. 11, question 1(f). 30 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 12.1. 31 Exhibit RPD-1, RPD's Record, p. 11, question 1(g). 32 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 1.6. 33 Ibid., item 13.1, p. 9. 34 Exhibit RPD-1, RPD's Record, pp. 240-243, p. 250. 35 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 5.9. 36 Exhibit RPD-1, RPD's Record, NDP for Nigeria (April 29, 2016), item 1.6. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD.25.02 (June 23, 2014) RAD File No. / N° de dossier de la SAR : TB6-18943 TB6-18944 TB6-18945 TB6-18946