TC1-12880

RAD File / Dossier de la SAR : TC1-12880 Private Proceeding / Huis clos Reasons and Decision ? Motifs et décision Person who is the subject of the appeal XXXX XXXX XXXX Personne en cause Date of decision March 10, 2022 Date de la décision Panel Nathan Ferguson Tribunal Counsel for the person who is the subject of the appeal Nicholas Owodunni 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] The Appellant, XXXX XXXX XXXX, is a 34-year-old citizen of Nigeria who alleges that he fears the Reformed Ogboni Fraternity (ROF), who attempted to force him into joining their fraternity, kidnapped and tortured him for several days, threatened his life, and killed or were involved with the death of his uncle. The Refugee Protection Division (RPD) denied his claim for refugee protection on the basis that he did not credibly establish that he faced a serious possibility of persecution as he alleged or that he was subjected personally to a risk to life or a risk of cruel and unusual treatment or punishment or to a danger of torture. The Appellant asks that the Refugee Appeal Division (RAD) substitute a finding that he is a Convention refugee or a person in need of protection. Alternatively, the Appellant asks that the RAD refer the matter back to a differently constituted panel of the RPD for redetermination. DECISION [2] I dismiss the appeal. The RPD was correct in finding that the Appellant is neither a Convention refugee nor a person in need of protection. I find that the determinative issue is the Appellant's credibility in establishing the persecution he alleges. BACKGROUND [3] The Appellant alleges that after his father's death in XXXX 2017, he became aware that his father was a member of an organization the Appellant knew as the Ogboni Fraternity. On XXXX XXXX, 2018, a Mr. XXXX identified himself as a member of this fraternity and met privately with the Appellant to invite him to take his father's place. At that time, he was given "time to think about it" according to his basis of claim narrative. The Appellant understood this to be a social group or organization. Mr. XXXX invited the Appellant to attend a meeting on XXXX XXXX, 2018.1 [4] At the XXXX XXXX, 2018 meeting, the Appellant alleges that two new members were initiated, and a part of this initiation ceremony was the offering of human body parts. The Appellant testified that he saw a human hand and breast offered before fainting from shock.2 [5] The Appellant alleges he lost sleep for several days, but when he spoke with Mr. XXXX, he was assured this was not a "big deal," and new members must sacrifice whatever the gods demand because failure to provide the sacrifice might lead to death or madness. Mr. XXXX, accompanied by two other unidentified men, revisited the Appellant on XXXX XXXX, 2018, and told the Appellant to prepare for his own initiation on XXXX XXXX, 2019.3 The Appellant was concerned and spoke with his mother and uncle at this time. The Appellant's uncle advised him to "stay clear" of the group.4 [6] A few days before the Appellant's scheduled initiation, Mr. XXXX attended his home and reminded him of the date. According to his basis of claim narrative, he refused at this time, and Mr. XXXX laughed and informed him that "nobody refused."5 The Appellant did not attend the initiation on XXXX XXXX, 2019. [7] On XXXX XXXX, 2019, the Appellant alleges he was kidnapped by several young men and forced into a car that drove him to an unknown location. He was blindfolded, gagged, and tied to a chair for three days without food or water. The Appellant alleges his captors "tortured [him] severely" during that time.6 On the fourth day, one of his kidnappers opened a window in the room, unbound the Appellant's hand so that he might eat and left the room for unknown reasons. At that time, the Appellant alleges he was able to escape through the window, ran to a road, was picked up by a motorcyclist and eventually transported by taxi to his uncle's home.7 [8] The Appellant and his uncle attended a police station on XXXX XXXX, 2019, and reported all of these events. The police allegedly arrested Mr. XXXX and requested the Appellant and his uncle attend to identify him, which they did. Approximately one week later, the Appellant spoke with the police again to inquire about the status of the investigation and was told to "forget about it." 8 He and his uncle concluded the police had no power over the fraternity, and he decided to stay with a friend of his uncle in another city. [9] The Appellant's mother advised him on XXXX XXXX, 2019, that she was receiving threats on a daily basis. His uncle's friend advised him that his uncle reported the fraternity was asking for him.9 In XXXX of 2019, his mother called the Appellant and told him the fraternity visited his uncle.. After this meeting, he was dead.10 The Appellant decided to move to a larger city with another friend. The Appellant's uncle's friend called and said that the fraternity inquired about his whereabouts. At this point, the Appellant decided to leave the country. He arrived in Canada on XXXX XXXX, 2019, having travelled through the US.11 [10] The Appellant submits no new evidence and does not request an oral hearing. ANALYSIS [11] My role is to look at all the evidence and decide if the RPD made the correct decision.12 Having considered the Appellant's arguments and the entire record available to me, I find that the determinative issue is the credibility of the persecution or risk alleged by the Appellant. The agent of persecution is the ROF [12] The Appellant did not challenge or dispute the RPD's finding that the organization he fears is the ROF. This is also corroborated in the affidavits of his sister, his uncle's friend, and his mother's neighbour.13 Although the Appellant argued that he did make out his fear of persecution, he did not direct me to any objective evidence that contradicts the RPD's findings that the ROF is distinct from the "traditional Ogboni society"14 nor that it is not a cult or secret society, has open membership, does not include forced recruitment and does not automatically make members of existing members' children.15 The Appellant's argument on this point states: ...The panel's conclusions that the ROF is not a secret society remains to be seen in fact. The panel's reference to the newspaper report is only one of a handful curiosity and leaning in the direction to deny the claim. The newspaper appears to be a local unsophisticated publication which avoids specificity on the sensitive issue of Ogboni and the appellant's alleged persecution.16 [13] I understand the reference made to the newspaper publication to be the XXXX XXXX article provided by the Appellant. I find the article's applicability to the question of the ROF's function as a secret society unclear. It does not provide information on this point.17 [14] In making this finding, the RPD referred to several objective items included in the country documentation package that the Appellant does not address in his argument.18 I am aware of the removal of item 13.6 from the documentation package dated November 30, 2021. Item 13.13 has also been updated. There is no material change to the RPD analysis regarding the ROF. The current objective documentation continues to identify the ROF as a distinct entity from the Ogboni society, states that membership within the ROF is "not compulsory" for spouses or children, and confirms that membership is "not inherited."19 Credibility findings [15] A witness providing testimony under oath or affirmation is presumed to be truthful. However, this presumption is rebuttable in the event that the witness fails to provide an adequate explanation for inconsistencies, omissions or other reasons that call into question the truthfulness of their testimony.20 In this instance, I find that there are material inconsistencies and omissions in the Appellant's evidence that he did not adequately explain and that the objective evidence available is not reconcilable with his account of the persecution he faces. I also find that the Appellant's documentation provided was not persuasive regarding his allegations of persecution as this did not corroborate the most significant details about which he testified. As a result, I find that the Appellant's credibility was significantly undermined, and the presumption of truthfulness was rebutted. Police report is not reconcilable with the Appellant's allegations [16] The police report provided by the Appellant indicates that he attended with his uncle on XXXX XXXX, 2019, and reported that his life was threatened by his late father's friend Mr. XXXX and members of the confraternity who were attempting to force him to join.21 The police report does not include any detail regarding kidnapping, torture, escape or human sacrifice. I agree with the Appellant that the content of the police report is not something that was within his control and should not have been treated as an omission on his part.22 However, in my view, the police report does include a significant material discrepancy for which the Appellant did not explain. As such, even though the credibility finding was categorized incorrectly in my view, I find that the result that this negatively impacted the credibility of the Appellant is correct. [17] The Appellant argues that he cannot be expected to account for the content of the police report or what they take down from his account of the incidents he described. While I agree that the Appellant is not the author of the report and does not control the content directly, the incidents that he testified he described to the police are the basis of his allegation that he is at risk because of the ROF. I would not expect the police report to repeat his account exactly, but it would be reasonable to expect the broad allegations would be included. [18] The police report provided makes no reference to the initiation meeting or human parts rituals that the Appellant described, his allegations of kidnapping, his allegations of severe torture, or any detail of his escape from his captors. Rather, the police report states that the Appellant attended the police headquarters "...to report a threat to his life by his late father's friend, Mr. XXXX and the members of the Ogboni Confraternity". The report does not appear to have been hastily drafted or lack detail. Instead, the author provided an outline of the Appellant's father's membership in the fraternity, his death, the Appellant's allegation that he was under pressure to take over his father's position, that he refused due to his Christian faith, his mother's name and that his mother warned him against joining. [19] At the RPD hearing, the Appellant confirmed in his testimony that he told the police "everything" and specifically the details of the initiation, including the use of human parts, the details of his kidnapping and being held captive for days. Given the overall level of detail included in the report, I find that the absence of any reference to the initiation meeting, the rituals including human parts observed by the Appellant, or the Appellant's kidnapping, torture and dramatic escape, significant and material discrepancies from his Basis of Claim (BOC), and his testimony. [20] The Appellant was asked about the content of the report by the RPD and confirmed that he reviewed this before the hearing and made no effort or attempt to obtain any additional information or correction to the report. The Appellant was asked why he took no such action; he stated it did not cross his mind. I find that he did not explain this significant and material discrepancy between his account of the incidents and the evidence he provided to corroborate the same. This significantly undermines his credibility, in my view. The Appellant's BOC includes an unexplained material omission regarding Mr. XXXX warning or threat [21] The Appellant argues that there are no significant material omissions or discrepancies between his BOC and testimony. When asked about the differences outlined below, he testified that he did not intend to leave out any detail and understood that he might elaborate at the hearing, and it was a "mistake" not to include these details in his BOC. [22] The RPD considered several omissions material to the Appellant's allegations regarding the risk he faces and determined that these undermined his credibility. The Appellant argues that this is microscopic, overly focused on minor concerns and that he ought to be allowed to flesh out the details of his account in a hearing. He argues that omission alone is not sufficient to impugn credibility, and the BOC should not be treated as a memory test.23 [23] While the Appellant's BOC does outline that he attended the ROF initiation meeting on XXXX XXXX, 2018, he observed a ritual involving the use of human body parts, and that he fainted as a result of shock, it does not include any reference to any threat or caution against discussing this incident. The Appellant's BOC indicates that he spoke with Mr. XXXX "some weeks" later and was told that the initiation ritual was not a "big deal" and was told he may die or go mad if he did not comply. [24] However, the Appellant provided a significantly different account of what happened after he fainted in his testimony. Specifically, when he woke up at the meeting, Mr. XXXX warned him he should not discuss the details of the meeting with anyone. He testified that Mr. XXXX told him at this time that he would die or go mad if he refused to join. When the RPD asked why he did not go to the police after this meeting, he explained that he was afraid, and Mr. XXXX had warned him not to tell anyone. [25] I agree with the Appellant that an omission in isolation does not impugn an individual's credibility. However, an explanation must be provided where there is a material omission. In this instance, I find the Appellant's explanation that it was simply a mistake not to include these foundational details regarding the reason for his fear of the ROF is insufficient. A person cannot be expected to provide perfect recall and certainly might overlook details in preparing a BOC. The Appellant was asked at the outset of this hearing if he understood the content of his BOC, and he testified that he did and that the BOC was complete, true and correct. I consider the omission of this warning significant because it goes directly to the fear or trepidation the Appellant allegedly experienced immediately. I do not accept the Appellant's explanation that this was a simple mistake, and as a result, I find that this negatively impacts his credibility. The Appellant's inaction is not sufficient to undermine his credibility [26] On the other hand, I agree with the Appellant that the RPD was too critical in negatively assessing his credibility based on his failure to take immediate action after the initiation meeting.24 If the Appellant did not receive a warning at the initiation and did not speak to Mr. XXXX for weeks, it might well be that he saw no reason to take any specific action. Similarly, if he were suffering from a lack of sleep, nightmares and shock as he described, whether or not he was warned not to tell anyone the details, he might have chosen to take no action. He might also have considered himself safe if he did not discuss the details with anyone. The Appellant testified that to this point, he considered the threats to be "talk" and not warrant any specific action. [27] The RPD concluded that a "disconnect between" the Appellant's testimony and action (or inaction) existed and made a negative credibility finding, though the RPD stressed that this was not determinative. I do not agree. While the Appellant's course of action after the initiation might not correspond to what the RPD expected, in my view, it was not so divergent as to be implausible or unbelievable. This aspect of his testimony did not negatively impact his credibility, in my view. The error in the Appellant's relationship included in an affidavit does not undermine his credibility [28] The Appellant argues that the RPD was microscopic and overly critical in assessing the affidavit dated XXXX XXXX, 2019.25 Specifically, the RPD focused on an error in the affidavit, which incorrectly described the Appellant's relationship to his uncle as "cousin" rather than a nephew. I agree with the Appellant that this is a minor error and ought not to negatively impact the overall credibility of the Appellant. The documents submitted by the Appellant are not persuasive Ika World News excerpts [29] I have reviewed the additional online articles submitted by the Appellant.26 I acknowledge that aspects of these articles contradict the objective country documentation referenced above. Specifically, two excerpts indicate that the ROF is a "secret cult," one of which also indicates "when member dies, his or her first son will succeed them." 27 I note that neither of these excerpts includes a byline or author. [30] As the RPD correctly noted, the articles are not vetted, the Appellant provided no testimony, nor did counsel make submissions establishing the relevance of these articles to the Appellant's circumstances, nor did they provide any information about the contributors or sources of information. It is also difficult to reconcile the articles' assertion that the ROF is a secret cult with the inclusion of the location of its head office, name of its leader and secretary, and details of its customs within the same articles. The objective evidence also indicates that corruption is an issue throughout the media in Nigeria, including blogs, magazines and newspapers.28 In light of the lack of identifiable authorship and detail regarding the publication, I find that these article excerpts are not persuasive and do not outweigh the objective evidence regarding the ROF. The affidavit evidence provided is not persuasive [31] The Appellant provided three affidavits, none of which is persuasive in establishing his allegations. The affidavit dated XXXX XXXX, 2019,29 states that the Appellant's uncle told the affiant the ROF threatened the Appellant's life and that the Appellant's uncle died a "mysterious" death. No details of either the wording of the threat or the manner of death are provided. No firsthand observation or detail is provided. While the affidavit indicates that the Appellant stayed with the affiant, no dates were provided. In short, the affidavit's content is vague. As outlined above, I agree with the Appellant that the RPD was microscopic in its evaluation of the credibility of the affidavit on the basis of a simple error in the relationship between the Appellant and his uncle. I find this is a minor error or inconsistency and does not impact the Appellant's credibility. However, the lack of direct knowledge expressed by the affiant and the lack of detail within the affidavit results in my finding that it should be given little weight in assessing the Appellant's allegations of persecution. [32] Similarly, the Appellant's sister provided an affidavit dated XXXX XXXX, 2019.30 This affidavit states that the ROF "made life difficult" for the Appellant and "threatened" him. The affidavit corroborates the Appellant's assertion and the content of the XXXX XXXX article, which states that "a relative" was interviewed in the creation of that article and indicates that Mr. XXXX attempted and failed to convince the Appellant to join the ROF. The Appellant's sister provided no details of how his life was made difficult nor the nature or content of the threat to her knowledge. She did not refer to the initiation meeting or kidnapping described by the Appellant. The Appellant's sister provided no direct knowledge or observation regarding the persecution the Appellant describes. [33] The Appellant argues that his sister's affidavit is appropriate and reliable, including her belief rather than her observation. As a result, he argues it should not have been discounted by the RPD.31 I do not find the content of the affidavit improper, misleading, or of any negative impact to the Appellant's credibility. I find that the affidavit does not establish or support his allegations regarding the persecution of the ROF and therefore gave it little weight for that purpose. [34] A friend and neighbour of the Appellant's mother also provided an affidavit in support of the Appellant dated XXXX XXXX, 2019.32 Again, the affidavit provides very little detail. The affiant states that she has observed attacks on the Appellant's family "on several occasions" while visiting their home, which was "led by XXXX," and that, according to the Appellant's mother, members of the ROF threatened the Appellant's life. This affiant also stated that the ROF "made life difficult" for the Appellant's family and especially the Appellant. [35] I note that the Appellant did not describe being attacked several times at his home. He also did not indicate that Mr. XXXX attacked him. Rather, his testimony is that he was kidnapped by "young men" and held for four days by unknown men. While he attributes responsibility to the ROF and Mr. XXXX, he did not describe any attack carried out personally by Mr. XXXX on him or his family. Additionally, the affiant provided no elaboration, including when or how the Appellant or his family were attacked. Given that the affidavit lacks detail, it is not in keeping with the Appellant's testimony, and it does not provide any firsthand knowledge of the incidents that the Appellant described as the persecution he faces; I gave this affidavit little weight in establishing the Appellant's allegations. The death certificate does not corroborate the Appellant's allegations [36] Additionally, the death certificate provided by the Appellant does not establish, corroborate or bolster his allegations. The death of his uncle is recorded; however, there is no information provided that suggests the connection of any member of the ROF or the ROF as a group. The cause of death is described simply as "unknown." I find that the death certificate did not suggest the involvement or responsibility of the ROF and gave it no weight in establishing the Appellant's allegations of persecution. The XXXX XXXX article is not persuasive [37] The article referenced in the Appellant's sister's affidavit was provided in a weekly issue of the XXXX XXXX.33 The article is dated after the Appellant left Nigeria. So after the date, he alleges he was kidnapped and had observed the initiation rituals he described. The article states that it is based on a family member's account. However, the article includes no details of the initiation meeting or the kidnapping, torture, and escape that the Appellant describes. Rather, the article indicates that the ROF was "harassing" the Appellant and that threats were sent regarding his life. The article also indicates that his uncle "died mysteriously" after a visit from members of the ROF. However, this source includes no details of the circumstances of the Appellant's death or how it may be attributed to the actions of the ROF. The article does not include a byline, and so it is anonymous both in its authorship and source, which detracts from its persuasiveness, in my view. [38] I further find that the article is significantly different from the Appellant's account of circumstances. In any event, I gave it no weight in establishing his alleged fear of the ROF as the details he relies upon in his BOC and testimony are not included in this article. The Appellant was not able to explain why the article does not include the details he described because he could not identify either the author or the source of the story. The tone of the RPD hearing was not inappropriate [39] The Appellant also argued that the RPD member was argumentative and created an adversarial hearing, especially in relation to his failure to report the initiation rituals to the police, intending to unnerve and shake the Appellant.34 I have reviewed the recording of the RPD hearing which took place over two separate dates, and find that the tone was not adversarial or confrontational. The RPD indicated at an early stage that credibility was an issue to be discussed, as is often necessary in this type of hearing. The RPD used an interpreter throughout to ensure the Appellant's understanding. While it is true that the Appellant was pressed for detail and explanation in several instances, this is often necessary when seeking an explanation for a perceived inconsistency or omission. Without putting these matters to the Appellant, there would be no opportunity to provide an explanation. The RPD was direct, even firm at times, but did not treat the Appellant as an adversary. The Appellant did not credibly establish his allegations of persecution by the ROF [40] For the reasons outlined above, I find that there are several material inconsistencies in the Appellant's account of the persecution he alleges from the ROF. First, the police report provided by the Appellant does not include any reference to his kidnapping, escape, or the initiation ritual he described. He did not explain this significant discrepancy and testified that he took no action to correct this report or obtain additional details. However, he reviewed the report before the hearing. This is a significant inconsistency that undermines his credibility as a result of his lack of explanation. [41] Second, the Appellant provided no explanation except that he made a mistake to account for the differing account he provided of the first time he received a threat or felt threatened by Mr. XXXX as between his BOC and his testimony. I find that this is a material omission that was not adequately explained and undermined his credibility on the whole. [42] Third, the death certificate provided by the Appellant does not establish any of the details of the persecution he alleged or make any reference to the responsibility of any third party for the death of his uncle. This is a central event because he testified his uncle's death finally prompted him to flee the country. However, the death certificate indicates only that the cause of death is "unknown," not that his uncle was killed or that the circumstances of his death were in any way unusual or attributable to the ROF. [43] Fourth, the additional documentation provided by the Appellant is largely vague, anonymous and fails to corroborate his account. The affidavit evidence and newspaper articles refer to information that the affiants and reporters did not observe firsthand and which are largely not consistent with the details of persecution that the Appellant provided - especially as they are silent on his kidnapping, torture and observation of a ritual involving the sacrifice of human parts. [44] Finally, the objective documentation regarding the ROF is not reconcilable with the Appellant's account of their action in this instance. This organization is described as having open membership and not being a secret organization or cult. Although the Appellant provided unvetted online articles that state the organization is secret, I found that these articles were not persuasive for the reasons above and did not outweigh the objective country documentation referenced herein. [45] Therefore, having reviewed the entire record, including the Appellant's testimony, the documentary evidence and the information available in the National Documentation Package and the documents filed by the Appellant, I agree with the RPD that the Appellant did not credibly establish his allegations of persecution and risk. The Appellant's claim fails on this basis. CONCLUSION [46] 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. (signed) Nathan Ferguson Nathan Ferguson March 10, 2022 Date 1 Exhibit RPD-1, RPD Record, Exhibit 2, at p. 29, paras 8-9. 2 Ibid., at pp. 29-30, at paras 10-11. 3 Ibid., at p. 30, para 15. 4 Ibid., at p. 30, para 16. 5 Ibid., at p. 30, para 17. 6 Ibid., at p. 30, para 19. 7 Ibid., at p. 31, para 21. 8 Ibid., at p. 31, paras 22-23. 9 Ibid., at p. 31, para 25. 10 Ibid., at pp. 31-32, para 28. 11 Ibid., at p. 32, para 34. 12 Canada (Citizenship and Immigration) v. Huruglica, 2016 FCA 93 (CanLII); Rozas del Solar v. Canada (Citizenship and Immigration), 2018 FC 1145 (CanLII). 13 Exhibit RPD-1, RPD Record, Exhibit 5, at pp. 120-121, 118-119, 122-123. 14 Exhibit RPD-1, RPD Record, RPD Reasons, at p. 13, para 26. 15 Ibid., at p. 13, para 26. 16 Exhibit P-2, Appellant's Record, at p. 104, para 25. 17 Exhibit RPD-1, RPD Record, Disclosure of Original Documents, at p. 162. 18 Exhibit RPD-1, RPD Record, Exhibit 3, National Documentation Package (NDP) for Nigeria (June 30, 2021), item 13.13: Nigeria: Ogboni society, including structure, rituals, ceremonies, and current status; membership and the consequences of refusing to join or trying to leave; relationship with police and judicial authorities (2017-April 2019), Immigration and Refugee Board (IRB), Response to Information Request (RIR) NGA106269.E, June 20, 2019, at p. 2; Ibid., item 13.6: Nigeria: The Reformed Ogboni Fraternity (ROF), including the nature of its belief system and its purpose; whether membership is compulsory, especially for children of members, and consequences for refusing to join the ROF; whether positions within the ROF are inherited, IRB, RIR NGA104054.E, April 13, 2012, at p. 6. 19 Exhibit RPD-1, RPD Record, Exhibit 3, NDP for Nigeria (June 30, 2021), item 13.13, supra, endnote 18, at pp. 8-9. 20 Maldonado v. Canada (Minister of Employment and Immigration) (1994), 23 Imm LR (2d) 220 (FCTD); Gill v. Canada (Minister of Citizenship Immigration), 2004 FC 1498 (CanLII), at para 25. 21 Exhibit RPD-1, RPD Record, Exhibit 5, at p. 124. 22 Exhibit RPD-1, RPD Record, RPD Reasons, at pp. 9-10, para 17; Exhibit P-2, Appellant's Record, at pp. 102-103, para 22. 23 Exhibit P-2, Appellant's Record, at pp. 101-102, paras 19-21. 24 Exhibit P-2, Appellant's Record, at p. 100, para 17; Exhibit RPD-1, RPD Record, RPD Reasons, at pp. 8-9, para 15. 25 Exhibit RPD-1, RPD Record, Exhibit 5, at pp. 118-119. 26 Exhibit RPD-1, RPD Record, Disclosure of Original Documents, at pp. 145-164. 27 Exhibit RPD-1, RPD Record, Exhibit 4, at pp. 97-98, 101-102. 28 Exhibit RDP-1, RPD Record, Exhibit 3, NDP for Nigeria (June 30, 2021), item 11.5: Brown envelope journalism, including types of publications that are affected; efforts to combat the phenomenon (2015-November 2017), IRB, RIR NGA106001.E, November 3, 2017, at p. 4. 29 Exhibit RPD-1, RPD Record, Exhibit 5, at pp. 118-119. 30 Ibid., at pp. 120-121. 31 Exhibit P-2, Appellant's Record, at p. 103, para 23. 32 Exhibit RPD-1, RPD Record, Exhibit 5, at pp. 122-123. 33 Exhibit RPD-1, RPD Record, Disclosure of Original Documents, at p. 162. 34 Exhibit P-2, Appellant's Record, at p. 99, para 16. --------------- ------------------------------------------------------------ --------------- RAD File / Dossier de la SAR : TC1-12880 RAD.25.02 (August 20, 2021) Disponible en français 2 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 (August 20, 2021) Disponible en français