TB6-00704

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 : TB6-00704 Private Proceeding / Huis clos Reasons and decision ? Motifs et décision Person(s) who is(are) the subject of the appeal XXXX XXXX XXXX Personne(s) en cause Appeal considered / heard at Toronto, Ontario Appel instruit à Date(s) of hearing June 9, 2016 Date(s) de l'audience Date of decision August 26, 2016 Date de la décision Panel S.S. Kular Tribunal Counsel for the person(s) who is(are)the subject of the appeal Johnson Babalola Barrister and Solicitor 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) appeals a decision of the Refugee Protection Division (RPD) denying her claim for refugee protection. [2] The Appellant asks the Refugee Appeal Division (RAD) to find her to be a Convention refugee or a person in need of protection. In the alternative, the Appellant asks the RAD to refer the matter back to the RPD for redetermination by a differently constituted panel. [3] The Appellant is relying on new evidence pursuant to section 110(4), and she is requesting an oral hearing1 pursuant to section 110(6) of the Immigration and Refugee Protection Act (IRPA or the Act).2 [4] The Minister is not intervening in this appeal. DETERMINATION [5] Pursuant to section 111(1)(b) of the IRPA, the RAD substitutes its own decision for that of the RPD and determines that the Appellant is a Convention refugee. This appeal is allowed. BACKGROUND/ALLEGATIONS [6] The Appellant alleged before the RPD that, upon return to Nigeria, she will be persecuted or harmed because of her sexual orientation as a bisexual woman. For details, refer to the Appellant's Basis of Claim (BOC) form.3 The Appellant provided additional information at the RPD hearing. [7] The Appellant's claim for refugee protection was heard on December 9, 2015. By a decision of December 31, 2015, the RPD rejected the claim. The RPD found the Appellant to be not credible regarding her sexual orientation as a bisexual woman. The Appellant submits that the RPD erred by mischaracterizing, misstating and ignoring relevant evidence that directly contradicted the conclusion that the RPD reached.4 ANALYSIS Role of the RAD [8] The Canadian jurisprudence 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 the RPD, a first-level administrative tribunal. [9] On March 29, 2016, the Federal Court of Appeal (FCA) in Huruglica5 provided guidance on how the RAD is to properly approach its review of the RPD's findings of fact or of mixed fact and law. The Court held that the task of the RAD is to determine whether or not the RPD was wrong in law, fact or in mixed fact and law, and in the context of the legislation. "Wrong" means "not true", "incorrect" or "mistaken", all of which "definitively points to the standard of correctness." [10] In closing, Justice Gauthier wrote: 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.6 [11] Justice Gauthier rejected the high level of deference (measured by "palpable and overriding error") found in the Supreme Court of Canada (SCC) decision in Housen v. Nikolaisen 2002 SCC 33. Regarding the credibility of the oral evidence heard by the RPD, Justice Gauthier stated that the provisions of the IRPA, particularly with respect to paragraph 111(2)(b) concerning the question of when the RAD may refer a matter back to the RPD for redetermination, does acknowledge the fact that: [In] some cases where oral testimony is critical or determinative in the opinion of the RAD, the RAD may not be in a position to confirm or substitute its own determination to that of the RPD.7 [12] Further, in a conclusion that may be obiter in the circumstances of Huruglica where the credibility of oral evidence was not in issue, the FCA found: This also recognizes that there may be cases where the RPD enjoys a meaningful advantage over the RAD in making findings of fact or mixed fact and law, because they require an assessment of the credibility or weight to be given to the oral evidence it hears. It further indicates that although the RAD should sometimes exercise a degree of restraint before substituting its own determination, the issue of whether the circumstances warrant such restraint ought to be addressed on a case-by-case basis. In each case, the RAD ought to determine whether the RPD truly benefited from an advantageous position, and if so, whether the RAD can nevertheless make a final decision in respect of the refugee claim.8 [13] Accordingly, the RAD will conduct its own assessment of the RPD's decision and come to an independent assessment of whether the RPD erred in its determination. The RAD will determine the appeal either by confirming the RPD's 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 will be referred back to the RPD for redetermination. The RAD will afford deference to the credibility findings of the RPD or to other findings only where the RPD has a particular advantage in reaching its conclusions. The extent of this deference will be assessed on a case-by-case basis, and that being dependent upon the particular circumstances of the matter and in conjunction with the RAD's own analysis of the record as a whole. [14] In conducting its own independent assessment and making the determination in this appeal, the RAD considered the entirety of the evidence submitted/adduced in this case, including the recording of the RPD's proceedings, the Appellant's submissions9 and the case law submitted with the appeal.10 Admissibility of evidence submitted on Appeal [15] As provided for in section 110(3) of the IRPA, with certain exceptions, the RAD must proceed without a hearing on the basis of the record of the proceedings of the RPD, and may accept documentary evidence and written submissions from the Minister and person subject to the appeal. Section 110(4) of the IRPA indicates that: "the person who is the subject of the appeal may present only evidence that arose after the rejection of their claim or that was not reasonably available, or that the person could not reasonably have been expected in the circumstances to have presented, at the time of the rejection." [16] The Appellant submitted two items as the proposed new evidence in support of her appeal. The documents are as follows: a. Affidavit of XXXX XXXX, sworn on February 3, 2016;11 and, b. 20 photographs.12 [17] The RAD Rule 3(3)(g)(iii) directs applicants to include an explanation of how the documentary evidence submitted to the RAD meets the requirements of section 110(4) of the Act and how that evidence relates to the Appellant. The Appellant provided an explanation as to why her alleged new evidence should be admitted at the RAD.13 [18] The RAD's analysis of the admissibility of the proposed new evidence begins with the test set out in section 110(4) of the IRPA. The RAD is also guided by the Federal Court of Appeal decision in Singh.14 The Court has held that in addition to the statutory requirements, further analysis of the evidence is required before the RAD can accept the proposed new evidence. Thus, in this regard, the RAD is guided by the analysis as set out in Raza15 and modified by the FCA in Singh. [19] The RAD assessed the newness, credibility, and relevance of the evidence. The RAD finds that the Appellant's above documents were not available to her at the time of the RPD hearing or at the rejection of her claim. The Appellant effectively entered into the same-sex relationship with XXXX XXXX after she had already received the rejection of her claim. The RAD finds that the Appellant has established that the documents proposed as new evidence arose after the rejection of her claim, and thus the RAD finds that the documents were not reasonably available to the Appellant at the rejection of her claim, therefore the Appellant could not reasonably have been expected in the circumstances to have presented these documents at the time of the rejection of her claim. The affidavit from XXXX XXXX is a sworn statement, and the photographs corroborate their alleged relationship. Based on the above analysis, the RAD finds that the Appellant's proposed new evidence meets the tests set out in the statutory requirements and in Raza. [20] Based on the above analysis, the RAD admits the Appellant's evidence. The materiality of the evidence will be considered in the context of the assessment of the evidence made under section 110(6) of the IRPA. Application for oral hearing at the RAD [21] Section 110(3) of the IRPA requires that the RAD proceed without a hearing, on the basis of the RPD's record, while allowing the RAD to accept documentary evidence and submissions from the Minister and the Appellant. The person who is the subject of the appeal may, pursuant to Section 110(4), present only evidence that arose after the rejection of their claim or that was not reasonably available, or that the person could not reasonably have been expected in the circumstances to have presented, at the time of the rejection. When read together, however, Sections 110(3), (4), and (6) establish that the RAD must not hold a hearing in an appeal unless there is new evidence (section 110(4)), in which case the RAD may hold a hearing if that new evidence raises a serious issue with respect to the credibility of the Appellant, is central to the RPD's decision, and that, if accepted, would justify allowing or rejecting the refugee protection claim (section 110(6)). The Appellant has provided new evidence as per Section 110(4) of the IRPA; the RAD has admitted the Appellant's new evidence. [22] The RAD considers the Appellant's new evidence in the context of the totality of the evidence submitted/adduced at the RPD, including the testimony of the Appellant, and the Appellant's Record. The RAD finds that these documents are relevant to the core aspects of the claim. In consideration of the country conditions documentation, and the Appellant's new evidence admitted at the RAD, if found to be credible, it may lead the RAD to accept the Appellant to be a Convention refugee. In this regard, even if the RAD were to find the Appellant's evidence relating to the incidents in Nigeria to be not credible, the RAD may still find the Appellant to be a refugee sur place. Therefore, the RAD finds that the new evidence admitted raises a serious issue with respect to the credibility of the Appellant's allegations, and is central to the Appellant's refugee claim; therefore, the RAD proceeds with the hearing. The Appellant's request for a hearing is allowed. Merits of the Appeal [23] The RPD accepted the Appellant's personal identity, and that she is a citizen of Nigeria.16 The RAD has reviewed the Appellant's identity documents in evidence and concurs with the RPD's finding. [24] Delay in leaving Nigeria: The RPD found that the Appellant's delay in leaving Nigeria and her failure to claim asylum in the U.S. are not consistent with a subjective fear of persecution.17 The RPD found that the Appellant's evidence in relation to her travel to Canada, her departure from Nigeria, and her failure to claim asylum in the U.S. and upon arrival in Canada was "evasive and at times highly convoluted".18 [25] Relating to the delay in leaving Nigeria, the Appellant submits the following arguments. The Appellant submits that the precipitating incident occurred on XXXX XXXX, 2015, and the Appellant left Nigeria on XXXX XXXX, 2015, i.e., 20 days later.19 The Appellant submits that she had to make travel arrangements, and gather money in the amount of $15,000 in order to leave Nigeria.20 The Appellant submits that in response to question 2(f) of his BoC form she explained that she left Nigeria immediately after all of her travel plans were finalized.21 The Appellant submits that, furthermore, she remained in hiding while waiting to depart Nigeria.22 The Appellant submits that the RPD overlooked the Appellant's evidence. The Appellant adds that, further, the delay was not excessive and was necessary for the Appellant to make the necessary arrangements to leave Nigeria.23 [26] The RAD finds that the Appellant's evidence submitted/adduced at the RPD corroborates her arguments provided above. The RAD finds that the RPD's findings relating to the Appellant's delay in leaving Nigeria are speculative and unjustifiable in consideration of the totality of the evidence. The RAD finds that the RPD does not provide cogent reasons nor point to any part of the evidence on record in support of its findings. Therefore, the RAD finds that the RPD's finding in this respect cannot be sustained. The RAD finds that the Appellant's delay in leaving Nigeria to be insignificant under the circumstances of this case. [27] The Appellant further submits that she was denied procedural fairness as the RPD did not put this concern to her at the hearing.24 In reviewing the evidence in this case, the RAD agrees with the Appellant and finds that the RPD erred by not raising delay in leaving as an issue at the hearing, and thus the RAD finds that the RPD erred in this respect. [28] Failure to claim asylum in the U.S.: The RPD found that the Appellant's failure to claim asylum in the U.S. is not consistent with a subjective fear of persecution. In this respect, the RPD found that the Appellant's evidence in relation to her travel to Canada was evasive and at times highly convoluted. [29] The Appellant testified at the RPD that she was following the instructions of the smuggler who planned her trip from Nigeria to Canada. The Appellant's agent had advised her that she would be travelling to Canada through the U.S. The Appellant came from Nigeria to the U.S.; and was advised to remain in the U.S. until her papers to travel to Canada were ready. The Appellant submits that she was relying on the advice of a professional agent. She testified that she had no knowledge of the refugee process in the U.S. or Canada.25 [30] The RPD's reasons for finding that the Appellant's delay in leaving Nigeria and her failure to claim asylum in the U.S. are not consistent with a subjective fear of persecution were that the Appellant's evidence in relation to her travel to Canada was evasive and at times highly convoluted.26 [31] The RAD finds that the Appellant's evidence submitted/adduced at the RPD corroborates her arguments provided above. The RAD finds that the RPD's findings relating to the Appellant's delay in leaving Nigeria and her failure to claim asylum in the U.S. are speculative and lack evidentiary basis. The RAD finds that the RPD does not provide cogent reasons nor point to any part of the evidence on record in support of its findings. Therefore, the RAD finds that the RPD's findings cannot be sustained. The RAD finds that the Appellant provided a satisfactory explanation as to why she did not claim asylum in the U.S. Therefore, the RAD finds that the Appellant's failure to claim asylum in the U.S. does not detract from her credibility. [32] In reviewing the totality of the evidence in this case, including the recording of the RPD proceedings, the RAD finds that the Appellant provided consistent and clear evidence as to why it took her 20 days to leave Nigeria and why she did not seek asylum in the U.S. [33] As per the FCA decision in Huruglica, the RAD may show deference to the credibility findings of the RPD where the RPD enjoys a meaningful advantage over the RAD in making findings of fact, or mixed fact and law because they require an assessment of the credibility and weight to be given to the oral evidence it hears. The RAD, however, carries out its own analysis of the record to determine whether the RPD erred."27 [34] In addition to finding that the RPD erred by not raising delay in leaving as an issue at the hearing, based on the totality of the evidence in this case, the RAD respectfully disagrees with the RPD, and finds that the Appellant's delay in leaving Nigeria and her failure to seek asylum in the U.S., in the Appellant's particular situation and circumstances, does not demonstrate a lack of subjective fear. The RAD finds that the Appellant provided a satisfactory explanation for both the delay in leaving Nigeria and her failure to claim asylum in the U.S. [35] Appellant's identity as a bisexual: The RPD wrote: When asked direct questions relating to sexual activity he [sic] did ultimately respond to questions, albeit with hesitation and clearly devising responses on the go which lacked spontaneity.28 She is not in any relationship in Canada. Her evidence relating to her claimed relationships with women in Nigeria lacked spontaneity, and were [sic] a virtual recitation of portions of her narrative, and lacked corroborating supporting detail. Her account of being caught with her female lover leading to her departure was not credible. She did not recall when this happened, was unable to recall the means of her claimed escape, where she travelled through on the way to her aunt's how long it took or other details that an escapee in such circumstances would be expected to recall.29 The panel considered the claimant's testimony in relation to her sexual orientation as a bisexual woman from Nigeria. The claimant presented as hesitant, and her evidence presented as contrived. Her answers were rehearsed and contrived and lacked spontaneity. In the panel's view the claimant's evidence was contrived to present as a bisexual woman in order to achieve a migration outcome. Her evidence in relation to same sex relations was not spontaneous and was extremely vague. The panel does not accept that the claimant is a bisexual woman as claimed.30 The claimant's evidence was vague and lacked the depth of knowledge that a bisexual person living in Canada would have, having come from a country where living as a lesbian openly would be at best difficult.31 [36] The RPD did not accept that the Appellant is a bisexual woman as alleged. The Appellant submits that the RPD made many errors, gave no examples to support its conclusions, and focused on peripheral issues in making its negative credibility findings relating to the Appellant's identity as a bisexual woman.32 [37] In reviewing the Appellant's testimony, the RAD is baffled by the RPD's 'reasons for decision', as summarized above. In reviewing the Appellant's testimony, the RAD finds that the Appellant answered every question asked by the RPD. Although it is correct that the Appellant did not know some of the details relating to her travel from Oghara to Benin to Abuja; the RAD finds that the RPD is incorrect in stating that the Appellant did not know when the incident happened and did not know the means of travelling from Oghara to Benin to Abuja. The Appellant clearly wrote in her BoC, and testified at the hearing that the incident occurred on XXXX XXXX, 2015. The Appellant's evidence also clearly establishes that she took a taxi from Oghara to Benin, and then took a bus from Benin to Abuja to travel to her aunt's house in Abuja. [38] The RPD did not accept that the Appellant is a bisexual woman. The RAD finds that the RPD based its findings on speculative premises, such as the Appellant was hesitant, devising responses, her answers were rehearsed and contrived, and that her testimony was vague. The RAD finds that the RPD's negative credibility findings relating to the Appellant's identity as a bisexual woman cannot be sustained because the RPD did not provide clear and cogent reasons and offered no significant reference to the evidence on record in support of its conclusions. [39] Based on the totality of the evidence in this case, the RAD respectfully disagrees with the RPD and finds that the RPD's negative credibility finding relating to the Appellant's identity as a bisexual woman cannot be sustained. [40] Appellant's personal documents submitted in support of her claim: The RPD gave no weight to the Appellant's personal documents submitted in support of her allegations, including her identity as a bisexual woman. The RAD finds that the RPD gave no intelligible reasons for dismissing those documents. It is incumbent on the decision maker to duly review and assess the credibility and probative value of the evidence submitted/adduced. [41] The Appellant submits: The panel made a gross error by entirely ignoring the important supporting documents that added veracity to the Appellant's claim, on the basis that it had already deemed that she was not a credible witness. The panel essentially first made a global finding that the Appellant was not credible and then used the finding to dismiss crucial supporting documents.33 [42] In this respect, the RAD agrees with the Appellant. The RAD finds that there is no indication in the RPD's reasons that it duly reviewed and assessed the Appellant's personal documents submitted. Therefore, the RAD finds that the RPD erred by not duly reviewing and assessing the credibility and probative value of the documents submitted in support of the Appellant's allegations, including her identity as a bisexual woman. The RAD assesses the Appellant's documents and finds that the documents corroborate the Appellant's allegations which the RAD finds to be credible. [43] The RAD held a hearing, and assessed the additional evidence admitted at the RAD. In reviewing the information provided by the Appellant's witness, the RAD had some concerns regarding the Appellant's relationship with the witness XXXX XXXX as alleged. The RAD requested further documents relating to the RPD claim of the witness XXXX XXXX. In reviewing the totality of the evidence, including all of the documents relating to the RPD claim of the witness XXXX XXXX on evidence, the RAD finds the Appellant to be credible relating to her sexual orientation. The RAD finds that the Appellant has established her identity as a bisexual woman from Nigeria. [44] The RAD assessed if the Appellant as a bisexual would be persecuted, or face a risk to her life or a risk of cruel and unusual treatment or punishment upon return to Nigeria. [45] In reviewing the documentary evidence,34 the RAD finds that Nigeria is a dangerous country for the LGBT community. The Nigerian Society is extremely homophobic. The government has statutes in place to severely punish LGBT persons. The RAD finds that the Appellant would not receive adequate state protection if she were to incur violence as a bisexual woman. All this taken together creates a precarious situation for this Appellant to live in safety as a bisexual woman in Nigeria. Therefore, the RAD finds that there is more than a mere possibility that the Appellant, as a bisexual woman, would be persecuted upon return to Nigeria. SUMMARY [46] The RAD finds that the RPD's reasons are replete with errors of fact and law. The RAD respectfully disagrees with the RPD's reasons relating to most of the RPD's negative credibility findings. The RAD also finds that the RPD erred by not duly reviewing and assessing the credibility and probative value of the Appellant's documents submitted in support of her allegations, including her identity as a bisexual woman. [47] Based on the analysis provided above, the RAD cannot confirm the RPD's determination of the Appellant's claim. [48] The Appellant asks the Refugee Appeal Division (RAD) to find her to be a Convention refugee or person in need of protection. [49] Based on the totality of the evidence submitted/adduced in this case, the RAD finds that the Appellant has established her identity as a bisexual woman from Nigeria. Based on an independent assessment of the totality of the evidence in this case, the RAD substitutes its own decision for that of the RPD, and finds that the Appellant is a Convention refugee pursuant to section 96 of the IRPA. DISPOSITION [50] Based on the foregoing analysis and reasons, the RAD substitutes the decision pursuant to section 111(1)(b) of the IRPA, and determines that the Appellant is a Convention refugee. [51] This appeal is allowed. (signed) 'S.S. Kular' S.S. Kular August 26, 2016 Date 1 Exhibit P-2, Appellant's Record, Item 4, Affidavit of XXXXX XXXXX XXXXX, at pp. 12-15. 2 Immigration and Refugee Protection Act, S.C. 2001, c. 27, last amended on February 6, 2014. 3 Exhibit RPD-1, RPD's Record, at pp. 11-25. 4 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 3, p. 110. 5 M.C.I. v. Huruglica, Bujar (F.C.A., no. A-470-14), Gauthier, Webb, Near, March 29, 2016, 2016 FCA 93. 6 Ibid., at para. 103. 7 Ibid., at para. 69. 8 Ibid., at para. 70. 9 Exhibit P-2, Appellant's Record. Item 6, Appellant's Memorandum of Argument, at pp. 109-138. 10 Exhibit P-2, Appellant's Record, Item 5, Appellant's List of Authorities, at pp. 107-108. 11 Exhibit P-2, Appellant's Record, Item 4, Exhibit C, Affidavit of XXXXX XXXXX, at pp. 99-101. 12 Exhibit P-2, Appellant's Record, Item 4, Exhibit C, at pp. 102-106. 13 Exhibit P-2, Appellant's Record, Item 4, Affidavit of XXXXX XXXXX XXXXX, at pp. 12-15; Item 6, Appellant's Memorandum of Argument, at paras. 77-80, p. 136. 14 Singh, Parminder v. M.C.I. (F.C.A., no. A-512-14), Nadon, Gauthier, de Montigny, March 29, 2016, 2016 FCA 96. 15 Raza, Syed Masood v. M.C.I. (F.C.A., no. A-11-07), Linden, Sharlow, Ryer, December 6, 2007, 2007 FCA 385. 16 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 17, p. 7. 17 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 22, p. 8. 18 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 22, p. 8. 19 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 18, p. 113. 20 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 21, p. 114. 21 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 22, p. 114. 22 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 24, p. 115. 23 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 26, pp. 115-116. 24 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 28, p. 116 25 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 30, p. 117. 26 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 22, p. 8. 27 M.C.I. v. Huruglica, Bujar (F.C.A., no. A-470-14), Gauthier, Webb, Near, March 29, 2016, 2016 FCA 93, at paras. 70 and 103. 28 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 24, p. 8. 29 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 25, p. 9. 30 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 26, p. 9. 31 Exhibit P-2, Appellant's Record, Item 3, Reasons for Decision, at para. 27, p. 9. 32 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at paras. 40-62, pp. 122-131. 33 Exhibit P-2, Appellant's Record, Item 6, Appellant's Memorandum of Argument, at para. 64, p. 132. 34 Exhibit RPD-1, RPD's Exhibits, RPD Exhibit 3, National Documentation Package for Nigeria (17 July 2015). --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD File No. / N° de dossier de la SAR : TB6-00704