MB8-00642

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 / Dossier de la SAR : MB8-00642 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 Ottawa, ON Appel instruit / entendu à Date of decision October 30, 2018 Date de la décision Panel Susan Brown Tribunal Counsel for the person(s) who is(are) the subject of the appeal Solomon Orjiwuru Conseil(s) (de la/des) personne(s) 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 XXXX (Appellant), a citizen of Cameroon, appeals a decision of the Refugee Protection Division (RPD), dated September 26, 2017, rejecting his claim for refugee protection. The Appellant fears persecution on the basis of his political opinion as a member of the Southern Cameroons National Congress (SCNC). The RPD did not find the Appellant's claim credible. The Appellant submits new evidence under section 110(4) the Immigration and Refugee Protection Act (IRPA) and applies for a hearing under section 110(6). I do not accept the new evidence and the hearing application is denied. Following my independent assessment of the evidence, testimony and arguments of the Appellant, I dismiss the appeal and confirm the decision of the RPD that the Appellant is neither a Convention refugee nor a person in need of protection. BACKGROUND [2] According to his Basis of Claim Form (BOC) 1 the Appellant was born in XXXX in 1994. The Appellant joined the SCNC on XXXX XXXX, 2013. As an active member of the SCNC the Appellant says that he participated in activities including attending meetings, rallies and disseminating information and propaganda. As a result of his SCNC membership and activities, the Appellant says he was targeted by the Cameroonian authorities and was arrested, detained and mistreated. [3] In January 2017, fearing that he was being monitored at work, the Appellant quit his job and went into hiding. In February 2017, the Appellant was contacted by Al Jazeera via twitter soliciting comment on the unrest in Anglophone Cameroon. He gave Al Jazeera a video clip, an excerpt from which made it to the news program The Stream on XXXX XXXX, 2017. The Appellant left Cameroon on March XXXX, 2017 to study in Canada. His claim for refugee protection was received on June 19, 2017. The RPD hearing was held on August 10, 2017 and its decision rendered on September 26, 2017. SCOPE OF THE RAD REVIEW [4] The Refugee Appeal Division (RAD) reviews decisions of the RPD on a standard of correctness after conducting an independent assessment of the evidence before it.2 The exception to this rule is where the RPD enjoys a meaningful advantage in assessing and weighing the oral testimony heard, which in particular cases attracts a standard of review of reasonableness adapted to the RAD.3 Unless specifically stated below, I have applied the correctness standard. ADMISSIBILITY OF NEW EVIDENCE PRESENTED ON APPEAL [5] Section 110(4) of the IRPA provides that the Appellant 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. In Singh4 the Federal Court dictates a narrow interpretation of section 110(4): the conditions set out therein must be met and there is no room for discretion on the part of the RAD. If the section 110(4) threshold is met then the new evidence must also meet jurisprudential requirements of credibility, relevance and newness.5 [6] The Appellant submitted the following documents as new evidence pursuant to subsection 110(4)(New Documents A-C): A. Simplice Magloire Essomba Fouda, "Evaluating the Degree of Individual Bilingualism in Yaounde", Research on Humanities and Social Sciences, Vol. 2 2013. B. Peter Wuteh Vakunta, "Linguistic Apartheid and the Quest for Freedom and Identity in Cameroon", Postline News, (December 14, 2014), online: <www.postnewsline.com>. C. Letter dated May 11, 2017 from SCNC regarding the spelling error on the SCNC Membership Card. [7] I find that the Appellant's new evidence does not meet the statutory requirements of subsection 110(4). The RPD decision was rendered on September 26, 2017. All the new evidence pre-dates the RPD decision, was reasonably available and the Appellant could reasonably have been expected in the circumstances to have presented the information at the hearing. [8] In his submissions that Appellant acknowledges that all the new evidence was in his possession at the time of the hearing and would have been submitted to the RPD had spelling errors been raised as an issue at the hearing. In his submissions the Appellant says that the new evidence confirms that spelling errors are common in the English version of government documents but that he could not provide this evidence at the hearing as he was not aware of the RPD's concerns. [9] The RPD received 12 pieces of documentary evidence from the Appellant the day before the hearing, including photocopies or scans of the SCNC membership card and four of the police documents, and a further five documents, including another police document, on the day of the hearing. During the hearing the Appellant advised that the originals of the documents were in transit and would be submitted to the RPD on arrival. The RPD gave the Appellant until August 21, 2017 to submit the original document and made it clear that it would be reviewing them in detail.6 [10] I find disingenuous the Appellant's argument that it did not submit the new evidence prior to the rejection of the claim because the RPD did not identify spelling errors as an issue during the hearing for the following reasons: the RPD Rules7 require all evidence supporting a claim to be filed 10 days before the hearing, it is not RPD practice to accept responsive evidence as it arises during the hearing; he provided much of his evidence in contravention of the RPD Rules so too late for the RPD to finish its detailed review prior to the hearing; he only provided scans and photocopies prior to the hearing; the evidence is clear that the RPD had started a detailed review of the documents and was waiting for the originals to finish; and, RPD, RAD and Federal Court decisions demonstrate that spelling errors are a long standing issue in the assessment of the authenticity of Cameroonian documents. [11] The purpose of subsection 110(4) is to allow an appellant to provide the RAD with information that arose after the decision date, or was not reasonably available or that the appellant could not reasonably have been expected in the circumstances to have presented. Subsection 110(4) is not to be used to complete a deficient record submitted before the RPD.8 [12] For the reasons outlined above I do not accept the new evidence as it does not meet the section 110(4) threshold. ORAL HEARING AT THE RAD [13] The Appellant requests that the RAD hold a hearing. Section 110(6) of the IRPA says the RAD may only hold a hearing if there is new evidence that (a) raises a serious issue with respect to the credibility of the Appellant, (b) is central to the RPD's decision, and (c) if accepted, would justify allowing or rejecting the refugee protection claim. Since I do not accept the new evidence, the hearing request is denied. ANALYSIS [14] The determinative issue on this appeal is the credibility of the Appellant. [15] The RPD found that the Appellant was not credible for the following reasons: a number of the supporting documents submitted which were allegedly issued by public authorities were found on their face not to be authentic or reliable; the Appellant's testimony regarding the SCNC was not forthcoming and seemed rehearsed; and, it doubted the reliability of the Appellant's SCNC membership card, affidavit from the SCNC in support his claim, and letter from his aunt. [16] These findings caused the RPD to doubt the veracity of the Appellant's evidence and it concluded that the central allegations in the claim, that the Appellant was detained and is now wanted by the Cameroonian authorities due to his SCNC activities, were not, on a balance of probabilities, true. [17] The RPD also considered the risk faced by the Appellant if he were to return to Cameroon given that he was quoted in the Al Jazeera news report. Based on his own testimony that the authorities in Cameroon would not be able to identify him, the RPD found that the Appellant had not established that he would face a risk upon return. [18] The Appellant argues that the RPD erred in each of its credibility findings. [19] I have independently assessed the evidence, testimony and considered the arguments of the Appellant. While I find that the RPD did make some errors in its assessment of the Appellant's credibility, I find those errors were not determinative. I agree with the RPD's overall conclusion that the Appellant is not credible for the reasons that follow. Authenticity of supporting documents issued by public authorities [20] Five documents are at issue: a bail bond dated May 4, 2014 (2014 Bail Bond);9 a bail bond dated June 29, 2015 (2015 Bail Bond);10 an undertaking dated June 29, 2015 (Undertaking);11 a convocation dated April 9, 2017 (Convocation);12 and medicolegal certificate dated August 3, 2017 (Medicolegal Certificate).13 [21] I have reviewed the evidence and verified the specific findings of the RPD with respect to these documents: spelling and grammar errors, missing accents in the French text, inconsistencies between the documents and the stamps/seals, different signatures from the same person on three of the five documents, inconsistent handwriting in the same document, an altered date, misnaming of the national police in Cameroon. [22] This case presents circumstances where it may be appropriate for the RAD to show deference to the findings of the RPD.14 "[W]here the refugee claimant has presented an original document to the RPD but that document is not before the RAD, the RPD may have a meaningful advantage in assessing the veracity of that evidence".15 Specifically the RPD had an advantage with respect to its findings relating to: signatures, handwriting, alterations and determining that documents were colour printed and not printed on letterhead. I will defer to the RPD in its assessment of the authenticity documents, this means I will undertake my own analysis but decide on a reasonableness rather than correctness standard. [23] The Appellant makes the following arguments about the RPD's finding that the documents are not authentic or reliable: * He acknowledges the spelling, grammatical and syntactic errors on the face of the documents and argues that they are beyond his control and that there is no objective evidence that says that such errors invalidate the documents; * That a judge signing the Undertaking was not inconsistent with the document since it referenced the Judicial Police in the header and there was no objective evidence to show that this was not the usual practice; * Jurisprudence requires that there must be some reason or evidence to rebut the presumption that government-issued documents are valid and this must be more than statements in the NPD that fraudulent documents are generally available; * The National Documentation Package for Cameroon (NDP) says that the only way to confirm if documents are authentic is to contact the issuing authorities. [24] I have reviewed the evidence and the NPD and conducted my own assessment of the documents. 2014 Bail Bond [25] Although argued in the context of the Undertaking, the Appellant says that there was no objective evidence to show the practice or procedure associated with bail in Cameroon. This is not correct. According to the NDP, suspects detained by the police "can then be released unconditionally with the charges dropped, if the prosecutor does not find sufficient evidence against them; released on bail, or "provisionally," pending trial; or remanded in pre-trial detention."16 [26] The Cameroon Criminal Procedure Code (CPC) prescribes the manner in which bail is granted: Criminal Procedure Code, section 117: "At the close of the investigations, the suspect who has no known residence or who cannot fulfil any of the conditions referred to in section 246 (g) shall be arrested and taken before the State Counsel if there is strong corroborative evidence against him. A suspect who has a known residence or who fulfils one of the conditions provided for in section 246 (g) shall be released on bail;" Section 224 (1): "Any person lawfully remanded in custody may be granted bail on condition that he fulfills one of the conditions referred to in section 246 (g), in particular to ensure his appearance either before the judicial police or any judicial authority;" Section 246 (g): "in order to ensure his appearance he shall: - either deposit a sum of money, the amount and conditions of payment of which shall be fixed by the Examining Magistrate, taking into consideration the resources of the defendant; or provide one or more sureties in accordance with the provisions of sections 224 and following."17 (emphasis added) [27] The 2014 Bail Bond does not comply with two important elements of the CPC. Bail is fixed by the "Examining Magistrate" so the bail document is issued by a court and not the police and should have been signed by a judge and not the police commissioner. The most important aspect of the granting of bail, to ensure the Appellant's appearance either before the police or a judicial authority on a specific date, is not addressed as the appearance date is not filled in. 2015 Bail Bond [28] The 2015 Bail Bond is also offside with the CPC as it was issued by the police and not a court and should have been signed by a judge and not the police commissioner. Undertaking [29] The Undertaking is signed by a judge which is consistent with the CPC but it is issued by the national police (wrongly named as noted by the RPD) when it should have been issued by a court. I note that the Undertaking does not reference either the charge number, QC/600/2015, or the 2015 Bail Bond, in fact, there is nothing on the face of the Undertaking to link it to the Appellant's arrest or release on bail. Convocation [30] The NDP reference document the Appellant cites in his argument, a response to information request (RIR) on notices to appear in Cameroon,18 is very useful as it specifically addresses the characteristics of convocations (also known as notices to appear and summons) issued by the national police in Cameroon: the General Delegation for National Security. While notices to appear may come from a number of sources, the convocations provided as evidence by the Appellant were allegedly issued by the national police, the General Delegation for National Security. [31] According to the RIR, notices to appear issued by the national police have the following characteristics: * They must be signed by a judicial police officer and the signature is accompanied by a police seal and name stamp of the signatory;19 * A notice to appear includes an acknowledgement of receipt which must be detached and given to the recipient who must then sign it and return it to the judicial police officer; * Notices to appear have been harmonized for the entire territory and forms generally have the same information although their format and quality depend on the issuing service;20 * Notices to appear must be bilingual...in an Anglophone area, they start in English and the French follows, and in Francophone areas, the English follows the French...some units waive this bilingualism rule.21 [32] A sample notice to appear form (Sample Notice to Appear) is attached to the RIR22 with the following information fields to be filled in, the French is first followed by the English translation: Service; Summons No; Date and time; Judicial Police Officer; Name of investigation; Name of investigator; Reporting place, date and time; Name of person being summoned; and, Purpose of requirement to bring identification. The header of the document is two lines without any crests or shields. The first line says Republic of Cameroon and the second line says Peace-Work-Fatherland. The document makes reference to sections 79, 82-92, 103-115 of the CPC and gives a warning in the event of default with reference to section 195 of the CPC. [33] I note that the Convocation is nothing like the Sample Notice to Appear, for example: the header is four lines and includes a crest/shield; the following information is missing from the document: name of the judicial police officer; name of the investigation; name of investigator; and purpose of requirement to bring identification; there is no acknowledgement; and there is no reference in the document to the CPC. [34] I do not agree with the Appellant's argument that the onus was on the RPD to authenticate the Convocation. I note that the section of the RIR cited by the Appellant puts the requirement to authenticate a summons with the issuing authority in the context of "fraudulent notices to appear that are almost identical to the real notices to appear, except that they are not registered with a police station or issuing authority."23 In this case the Convocation is nothing like a genuine notice when compared to the Sample Notice to Appear attached to the RIR. The Appellant's Convocation does not fall into the category of notices that are almost identical to the Sample Notice to Appear and need authentication because it is nothing like a genuine notice to appear. Medicolegal Certificate [35] In addition to the issues identified by the RPD on the face of the Medicolegal Certificate I note a stark inconsistency between its content and the Appellant's BOC. In his BOC the Appellant says that he was carried unconscious to the hospital "... I passed out, they left me there...I was resustated [sic] in the hospital... besides physical examinations, some other tests were carried out on me."24 The Medicolegal Certificate says "...the patient was rushed to this facility...with swollen wrist and ankle and several bruises. Patient was placed under medical examination..."25 The Medicolegal Certificate does not reference either the resuscitation or identify any medical tests carried out on the Appellant. Summary [36] Contrary to the Appellant's arguments, I find that the RPD based its finding that the documents were not authentic or reliable on much more than spelling errors and objective evidence that fraudulent documents are readily available in Cameroon. [37] Based on my own review of the evidence and the objective evidence in the NDP on criminal procedure26 and notices to appear27 in Cameroon, I find valid reasons to rebut the presumption that these documents are valid as issued by a public authority and to find that the documents are fraudulent. These documents are the foundation of the Appellant's claim that he was detained and mistreated and is wanted by the police because of his SCNC affiliation. My finding that they are fraudulent undermines the credibility of the Appellant's claim. Testimony regarding the SCNC [38] The RPD found the Appellant's testimony regarding the SCNC not to be credible because it was not forthcoming and seemed rehearsed. [39] The Appellant argues that the RPD erred because it rejected the Appellant's evidence not because of its lack of credibility but because of its credibility and not based on what it says but on what it does not say. [40] I have reviewed the audio recording of the Appellant's testimony and do not agree with the RPD finding that the Appellant rephrased or repeated the question in an attempt to gain more time before answering. [41] On the issue of whether the Appellant's answers seemed rehearsed it is trite law that the demeanour of the claimant is not a decisive factor in assessing credibility. I do not find that the RPD conclusions, on the nature of the Appellant's testimony as rehearsed, play a role in the final assessment of the credibility of the Appellant. SCNC membership card and affidavit [42] The RPD doubted the reliability of the Appellant's SCNC Membership Card28 on the basis of spelling errors in the pledge. Since the objective evidence clearly demonstrates that authentic membership cards contain the errors identified by the RPD29 the reliability of the SCNC Membership cannot be impugned solely on that basis. [43] The RPD also doubted the reliability of an SCNC affidavit in support of the Appellant's claim (SCNC Affidavit)30 for the following reasons: the layout of the first and second pages of the document is different and are not printed on the same paper; and, it contains information inconsistent with the Appellant's evidence and BOC. [44] The Appellant argues that the RPD had a duty to verify the SCNC documents and not to draw negative inferences due to speculation and subjective views and that the information in the SCNC Affidavit was not inconsistent with the Appellant's evidence and BOC. [45] There is no duty on the RPD to have impugned documents authenticated.31 Furthermore, the Immigration and Refugee Board Research Directorate (SIRU) is not able to authenticate SCNC documents. Due to legal factors brought to its attention in 2017 SIRU is unable to send claimant information for verification to various authorities and organizations because private information has to be sent via a secure network which is not available for some foreign government authorities and organizations. [46] Despite the Appellant's general denial, there are clear inconsistencies between his evidence and the SCNC Affidavit. Except for the first issue, which the Appellant says was a typo, none of the issues identified below were addressed by the Appellant in his argument: * the SCNC Affidavit says the Appellant joined in 2015, his evidence and SCNC Membership Card says he joined in 2013; * the SCNC Affidavit says the Appellant was harassed and tortured on September XXXX, but the year is not identified, and that he was hospitalized at the Buea health centre, the Appellant's BOC says he was attacked on September XXXX, 2013 and hospitalized at the Muea Health Centre; * the SCNC Affidavit says that the Appellant was arrested on October XXXX, 2014 in XXXX, evaded another arrest on April XXXX, 2015 and was later arrested on June XXXX but the year is not identified, the Appellant's BOC says he was arrested on April XXXX, 2014 and released on May XXXX, 2014, evaded arrest on April XXXX, 2015 and arrested on June XXXX, 2015; * the SCNC Affidavit says that he was forced to flee his homeland when he realized that his family members had been targeted and arrested by the security men for failing to produce him, the Appellant's BOC makes no reference to his family members being targeted and arrested; and * the SCNC Affidavit says that the Appellant had been blacklisted, the Appellant's BOC and other CIC documents say that he had a job with the XXXX XXXX XXXX (XXXX) from March XXXX, 2016 until he left Canada in March 2017, working with Cameroonian government departments. [47] I find that the SCNC Affidavit is not a reliable document due to the many inconsistencies between it and the Appellant's evidence. I also note that while it purports be an affidavit it is not a sworn document nor was any corroboration of the identity of the author provided. [48] I find that the Appellant's SCNC Membership Card is not evidence of active participation in the SCNC and does not outweigh the negative inferences with respect to his credibility and SCNC membership in the face of the fraudulent documentation which impugns the credibility of the central aspects of his claim. Letter from the Appellant's aunt [49] The RPD rejected the letter from the Appellant's aunt (Aunt's Letter)32 due to its absence of security features, because it was not sworn although called an affidavit and was not accompanied by the aunt's identity card. [50] The Appellant argues that there is no legal requirement that every letter that comes before the RPD must be accompanied by a copy of the author's identity card to be considered authentic or to have probative value. [51] While the Appellant's argument is correct is it also trite law that sworn evidence has greater probative value than unsworn evidence and that corroboration of the identity of the author, especially when such corroboration is readily available, also adds to its value. [52] In this case the Aunt's Letter is not sworn, she did not provide corroboration of her identity, although readily available and cited in the letter, and there is also an inconsistency between the Appellant's BOC and testimony. The BOC references one convocation being left with his aunt, which Convocation was submitted as evidence. In his testimony at the hearing the Appellant was asked if the police had been back to his aunt's house after leaving the Convocation and he said "she did not tell me anything of that, so I am not sure if they came back."33 The Aunt's Letter references "numerous events of harassments from gendarmes who come in to deliver convocations and laying threats on me and my family in attempts to know his whereabouts." This inconsistency eliminates any probative value of the Aunt's Letter to support the Appellant's claim. Al Jazeera news report [53] When asked by the RPD how someone watching would know it was the Appellant in the 15 second excerpt in the Al Jazeera news report, The Stream,34 he testified that no one would know, that his intention was to get the information out while remaining anonymous. The RPD found, based on his own testimony, the authorities in Cameroon would not be able to identify the Appellant. [54] The Appellant argues that the RPD did not take into account his response to a question from his counsel when he said that his voice was not masked and that anyone who listened to the clip and knew his voice would know it was him. [55] I have reviewed the Appellant's testimony and it is very clear. He said "they did not give me a name and they just put - and they did not put my face, just a shadow, a dark shadow without a name...nobody can know it was me because that was my intention, for nobody to know that it was me, but let the information out."35 [56] I do not find the testimony that the Appellant is relying on in his argument, given in response to a question from his counsel at the end of the hearing, is as clear: COUNSEL : My question is you're listening to the audio that was played, or that was used as you testified, now was your voice masked in any way or was it left as it is? CLAIMANT: No, my voice was not masked, just my face was masked, so - my voice was just my voice, if anybody who knows my voice listens to it I think I am at risk, because if anybody who listens to it knows my voice or (inaudible) to find out the voice I think they will get to me through that.36 [57] There is no evidence on the record that the authorities in Cameroon have made any connection between the Appellant and the 15 second clip in the XXXX XXXX, 2017 Al Jazeera report and the Appellant's evidence was that it was his intention to hide his identity. I agree with the RPD that the Appellant has not established that he would face a risk if returned to Cameroon based on the Al Jazeera news report. CONCLUSION [58] I find that the Appellant was not credible with respect to the central aspects of his claim and has not demonstrated, on a balance of probabilities, that he was detained, mistreated and is being sought by the authorities on the basis of his political opinion as a member of the SCNC. I find that the Appellant has not established that he faces a serious possibility of persecution in Cameroon, or that, on a balance of probabilities, he is at risk to his life or risk of cruel and unusual treatment or punishment or danger of torture. [59] 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 IRPA. (signed) Susan Brown October 30, 2018 Date 1 RPD-1, RPD Record, pages 11-28, Exhibit 2. 2 Canada (Citizenship and Immigration) v. Huruglica, [2016] 4 FCR 157, 2016 FCA 93 (CanLII). 3 Ibid., and X (Re), 2017 CanLII 33034 (CA IRB). 4 Minister of Citizenship and Immigration v. Parminder Singh, 2016 FCA 96 (CanLII). 5 Ibid., and Raza v. Canada (Minister of Citizenship and Immigration), 2007 FCA 385 (CanLII). 6 RAD-1, RAD Record, Transcript of RPD Hearing, pages 36-38, 43-46. 7 Immigration and Refugee Board of Canada, Refugee Protection Division Rules, SOR/2012-256 (RPD Rules), section 34(3)(a). 8 Canada (Citizenship and Immigration) v. Singh, 2016 FCA 96. 9 RPD-1, RPD Record, page 163, Exhibit 7. 10 RPD-1, RPD Record, page 157, Exhibit 6. 11 Ibid., page 160. 12 Ibid., page 158. 13 Ibid., page 159. 14 Canada (Citizenship and Immigration) v. Huruglica, [2016] 4 FCR 157, 2016 FCA 93 (CanLII), X (Re), 2017 CanLII 33034 (CA IRB), paragraph 47. 15 X (Re), 2017 CanLII 33034 (CA IRB), paragraph 58 citing Jadallah v. Canada (Citizenship and Immigration), 2016 FC 1240 (CanLII) paragraph 54. 16 RPD-1, RPD Record, Exhibit 3, National Documentation Package for Cameroon, April 28, 2017 (NDP), document 6.6, Human Rights Watch, Guilty by Association. Human Rights Violations in the Enforcement of Cameroon's Anti-Homosexuality Law, March 2013, page 13. 17 Ibid., page 14, footnote 16. 18 RPD-1, RPD Record, Exhibit 3, NDP, document 10.1, Response to Information Request dated October 23, 2013, Cameroon: Notices to appear issued by the General Delegation for National Security (Delegation generale a la Surete nationale, DGSN), including the issuing procedure; the content and appearance of the notices to appear, and whether it is the same at all the police stations in the country; possiblity of obtaining a fraudulent notice to appear (2012-October 2013). 19 Ibid., page 2. 20 Ibid., page 4. 21 Ibid., page 4. 22 Ibid., page 7. 23 Ibid., page 5. 24 RPD-1, RPD Record, page 15, Exhibit 2. 25 RPD-1, RPD Record, page 159, Exhibit 6. 26 RPD-1, RPD Record, Exhibit 3, NDP, document 6.6, pages 13-14, footnote 16. 27 RPD-1, RPD Record, Exhibit 3, NDP, document 10.1. 28 RPD-1, RPD Record, pages 141-142, Exhibit 6. 29 RAD-2, Response to Information Request (RIR) Number: CMR106136.E, Date: 22 June 2018 Subject: Cameroon: The Southern Cameroons National Council (SCNC), including leadership, structure, objectives, activities, requirements and procedures to become a member; relations with authorities; location and contact information; documents issued to members, including letterhead, seal and authorized signatories (2015-June 2018), Copies of SCNC Membership cards from 2011 (Attachment), P-3, Appellant's Submissions on RIR CMR106136.E. 30 RPD-1, RPD Record, pages 143-144, Exhibit 6. 31 Culinescu v. Canada (Minister of Citizenship and Immigration), 1997 CanLII 5539 (FC). 32 RPD-1, RPD Record, page 164, Exhibit 7. 33 RAD-1, RAD Record, Transcript of RPD Hearing, page 30. 34 RPD-1, RPD Record, page 108, Exhibit 5. 35 RAD-1, RAD Record, Transcript of RPD Hearing, page 17. 36 Ibid., page 38. --------------- ------------------------------------------------------------ --------------- ------------------------------------------------------------ RAD File / Dossier de la SAR : MB8-00642 RAD.25.02 (August 08, 2018) Disponible en français 17 RAD.25.02 (July 05, 2018) Disponible en français