VB9-05588
The RAD confirmed the RPD: the Appellant failed to prove on a balance of probabilities that the agents of harm have the means and motivation to locate her in the proposed IFAs and failed to establish that relocation to Abuja or Ibadan would be unduly harsh; admitted new evidence was of limited weight and did not...
Source-derived case information.
- Citation
- VB9-05588
- Parties
- Appellant: XXXX XXXX XXXX XXXX; Respondent: Minister (Respondent)
- Court
- Refugee Appeal Division
- Jurisdiction
- Canada
- Judgment Date
- 5 October 2020
- Procedural Posture
- Refugee Appeal (rad) / Decision on Appeal (amended)
- Outcome
- Appeal dismissed; decision of the Refugee Protection Division confirmed
- Legal Topics
- Internal Flight Alternative (ifa), Admission of New Evidence, Standard of Review, Gender Related Persecution, Credibility Assessment, RAD Procedure
- Source Language
- en
Source-derived case record
Summary, issues, holding and outcome
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Parties
XXXX XXXX XXXX XXXX
Appellant
Minister (Respondent)
Respondent
Procedural Posture
Refugee Appeal (rad) / Decision on Appeal (amended)
Legal Issues
- 1 Whether proposed IFAs (Abuja, Ibadan, Benin City, Port Harcourt) negate risk under section 96/97 IRPA
- 2 Whether the Appellant met the Rasaratnam two‑pronged IFA test
- 3 Admissibility and weight of new evidence under RAD Rule 29 and s.110(4) IRPA
Ratio Decidendi
The RAD confirmed the RPD: the Appellant failed to prove on a balance of probabilities that the agents of harm have the means and motivation to locate her in the proposed IFAs and failed to establish that relocation to Abuja or Ibadan would be unduly harsh; admitted new evidence was of limited weight and did not raise a serious credibility issue warranting a hearing; therefore no Convention refugee status or need for protection under s.96/97 IRPA.
Court Disposition
Appeal dismissed; decision of the Refugee Protection Division confirmed
Orders
- RAD confirms RPD decision pursuant to IRPA s.111(1)(a)
- New evidence from Appellant's son admitted but given little weight; no hearing ordered under IRPA s.110(6)(a)
Full Case Text
Judgment text and source record
1 paragraphs
RAD File / Dossier de la SAR : VB9-05588 Private Proceeding / Huis clos Amended ? Amendés Reasons and decision ? Motifs et décision Person who is the subject of the appeal XXXX XXXX XXXX XXXX Personne en cause Appeal considered / heard at Vancouver, BC Appel instruit / entendu à Date of decision October 5, 2020 Date de la décision Panel Ron Liberman Tribunal Counsel for the person who is the subject of the appeal Ohene K Andoh 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 AMENDED OVERVIEW [1] XXXX XXXX XXXX XXXX (Appellant) appeals a decision of the Refugee Protection Division (RPD) dated June 27, 2019, rejecting her claim for refugee protection on the grounds of a viable Internal Flight Alternative (IFA) in Abuja, Ibadan, Benin City or Port Harcourt. I have conducted an independent analysis of all the evidence concerned, including the entire Appellant Record and the oral testimony. In making my decision, I have considered and applied the Chairperson's Guideline 4: Women Refugee Claimants Fearing Gender-Related Persecution (Gender Guidelines).1 I have determined the Appellant is neither a Convention2 refugee nor a person in need of protection under section 96 or section 97 of the Immigration and Refugee Protection Act (IRPA).3 BACKGROUND [2] The Appellant is a 49-year old female who alleges as follows: she fears returning to Nigeria as she has been targeted by criminals. The Appellant has raised seven children - four of her own, and three children of her deceased sister - and these children are now adults. In 2001, during a riot between persons of Hausa and Yoruba ethnicity, her father was attacked and her mother was kidnapped. The Appellant has not seen her mother since then. In 2014, the Appellant and her son, XXXX, were physically attacked by unknown criminals, who appeared to be aware that the Appellant's mother was missing. Following this, they started receiving strange calls and visits to their home demanding money and threatening that the son would be kidnapped if they did not comply. In XXXX 2016, the Appellant travelled to the United States. In 2017 during Easter, XXXX was kidnapped in Nigeria, and was forced to withdraw all his money from automated teller machines ATMs and to hand it over to the criminals. The Appellant fears for her safety, and she wishes to live in Canada with her adult children. Counsel also submits that, if returned to Nigeria, the Appellant would be stigmatized as a single woman heading her own household when living in the proposed IFAs, and would be vulnerable to risks of violence, harassment and abuse (psychological, physical and sexual), and trafficking. RPD findings [3] With regard to the proposed IFAs, the RPD found the Appellant's fears regarding the motivation and capacity of the criminals to locate her were speculative. The RPD found the objective evidence indicates persons fleeing non-state actors can relocate to large multi-ethnic and multi-lingual cities. The Appellant demonstrated that she is resourceful, independent, and self-sufficient. She is educated and owns three houses. The Appellant's profile indicates she would be able to relocate to one of the proposed IFAs, and although this may pose difficulties, it would not be unduly harsh. Appellant's arguments [4] The Appellant argues that the RPD erred in dismissing the motivation and capacity of the criminals to locate her as speculation, that the Appellant should be given the benefit of the doubt, and that the RPD erred in its objective assessment of the proposed IFAs. Counsel submitted that the psychological impact of living in fear of being located must be considered. Furthermore, Counsel submitted that the proposed IFAs would be objectively unreasonable, among other reasons, because the Appellant is single and female, because the Gender Guidelines must be considered, because unemployment in Nigeria is very high, and because the Appellant would need to live in hiding for an indefinite period of time. ROLE OF THE REFUGEE APPEAL DIVISION (RAD) [5] In accordance with the decision in Huruglica,4 when reviewing the decision of the RPD, I have applied a standard of correctness while conducting an independent assessment of the entirety of the evidence before me. Submissions received on July 15, 2020 [6] The Appellant submitted evidence under RAD Rule 29 of the Refugee Appeal Division Rules (RAD Rules).5 Submissions from Counsel were received on July 15, 2020. This was followed on July 17, 2020 by supplementary submissions from Counsel and a separate "Statement of Fact" document from the Appellant's son. The latter document is accompanied by identification in the form of a National Driver's License. [7] As regards the "Statement of Fact" from the son, which constitutes evidence, I must first consider under RAD Rule 29 (1) the document's relevance and probative value; (2) any new evidence the document brings to the Appeal; (3) whether the person who is the subject of the Appeal, with reasonable effort, could have provided the documents with the Appellant's Record. [8] The "Statement of Fact" relates to events which are alleged to have occurred in April 2020 and May 2020. It could therefore not have been provided with the Appellant's Record. It brings new evidence of matters which are relevant to the Appeal, and which potentially have probative value in respect of the Appellant's claim, as it recounts threats in 2 of the proposed IFAs. I therefore find that the requirements of RAD Rule 29 are met in respect of this evidence. [9] Section 110(4) of the Immigration and Refugee Protection Act (IRPA)6 also applies in this case when considering the admissibility of new evidence. Under this section, I am required to determine whether this is evidence that arose after the rejection of the claim, or was not reasonably available when the claim was rejected, or is evidence which the Appellant could not reasonably have been expected to present at the time of the rejection. If I find that the evidence meets the test in section110(4), I must also, in order to admit it, determine that the evidence meets the modified factors of credibility, relevance and newness as specified in Raza7 and Singh.8 [10] Since the "Statement of Fact" of the Appellant's son relates to events which post-date the RPD's decision, and could not reasonably have been provided before the RPD rendered its decision, I find this document also meets the requirements of section 110(4) of IRPA. [11] Moreover, I find this new evidence meets the modified Raza and Singh9 criterion of credibility, relevance, and newness. Although not a sworn statement, the new evidence has on the face of it some credibility as to its source because it is accompanied by identification for the writer. It is of some relevance in that it is capable of proving or disproving allegations that the Appellant is being pursued by unknown men, and it is new in the sense that it is capable of proving a fact that was unknown to the Appellant at the time of the RPD hearing. For these reasons, I admit this new evidence. However, since as explained further in this decision, I ultimately give it little weight, I find it does not raise a serious issue with respect to the credibility of the claim and therefore does not meet the requirements of IRPA section 110(6)(a) to hold a hearing. Therefore, I have decided that the RAD will not hold a hearing in this case. [12] As indicated, section 110(4) of IRPA relates to the admission of new evidence. Submissions of Counsel are not evidence. The RAD extended the deadline for perfecting an appeal in this case because of the COVID-19 pandemic. Therefore, I assess these submissions of Counsel as being timely under the requirements of RAD Rule 29, and I also find that they are relevant and of potential probative value under this Rule, for the same reasons as the "Statement of Fact" of the Appellant's son. I have therefore considered these submissions when making my decision. ANALYSIS IFA [13] In the course of the hearing, the RPD identified four possible IFAs: Abuja, Port Harcourt, Benin City, and Ibadan. [14] The test for assessing an IFA is two-pronged and is set out in the Federal Court of Appeal decision in Rasaratnam:10 (1) The Board must be satisfied, on a balance of probabilities, that there is no serious possibility of the claimant being persecuted in the part of the country to which it finds an IFA exists and/or the claimant would not be personally subject to a risk to life or risk of cruel and unusual treatment or punishment or danger, believed on substantial grounds to exist, of torture in the IFA. (2) Moreover, the conditions in the part of the country considered to be an IFA must be such that it would not be unreasonable in all the circumstances, including those particular to the claim, for him to seek refuge there. [13] Both prongs of the test must be satisfied in order to find that the Appellant has an IFA. First prong of the test: Risk of persecution or section 97 harm in the IFA location [14] Under the first prong of the test, the Appellants bear the burden of proof to show that they face a section 96 or 9711 risk in the entire country and specifically in the suggested potential IFA. [15] The sworn testimony of an Appellant is presumed to be truthful unless there is valid reason to doubt their truthfulness.12 Having examined the evidence in the Appellant Record and the oral testimony, I accept, as did the RPD, that the Appellant is credible as to the events that are described in her Basis of Claim (BOC). I also accept that the Appellant is genuinely fearful, should she return to Nigeria, as to what might befall her, as well as what might befall her children who still live there. [16] Counsel has requested that the Appellant be given the benefit of the doubt when assessing her sworn testimony. In my analysis, I have given her testimony and her BOC the presumption of truthfulness, as did the RPD. I would add that I do not find the RPD's analysis to have been unfair or imbalanced in any way. [17] As explained below, after due consideration of all the evidence, I agree with the RPD that the Appellant's fear that the agents of harm are able to locate her in the proposed IFAs is speculative. [18] As stated by the RPD, when the Appellant was asked who the criminals are who attacked her son in Nigeria, she stated that she did not know. Moreover, the Appellant has not explained how these men are able to locate her in the proposed IFAs. [19] The evidence is that in or about 2014, a group of unknown men attacked the Appellant's son, who was studying at XXXX XXXX, in her presence. This attack appears to be related in some ways to attacks by Hausas on the Appellant's father many years earlier in 2002. The Appellant further testified that in or around 2017, another group of unknown men abducted the same son. The reasons they abducted him have not been specified by the Appellant. She testified however that after he was abducted, when his captors heard a message she had sent for him, they looked through his phone, discovered he had money in his bank account, and then forced the son to withdraw cash using his bank card. I note that there is no further evidence as to the motivation of the second group of attackers, or how they may be connected to the earlier groups of men. [20] The Appellant has introduced new documents which I have accepted into evidence, in the form of a Statement of Facts from her son, to the effect that he has recently been threatened in Port Harcourt by another group of men, who stated that they were looking for his mother, and that men have also been searching for the Appellant in Benin City, as per other relatives. [21] According to this letter, the writer was not home in Port Harcourt at the time the men came. The information that the men were searching for the Appellant has been provided by a 15-year old, which in my view reduces the weight to be given to it. In the case of Benin City, the information about men searching for the Appellant also does not emanate from the writer of the letter. While the RPD may accept hearsay evidence, in my view the weight to be given to this evidence is also reduced by the fact that it is not first-hand. Although the Appellant's son states he found these events to be so troubling that he fled to another state, there is no indication that he attempted to report matters to the police, or to find out who these men might, even though he alleges that they somehow located him subsequently in Ogun State, and also alleges that family members in Benin City were visited by unknown strangers seeking the Appellant; there is no indication that the police have been informed, or are investigating any of these events. [22] I note there is also no evidence of a connection between the disparate groups of unknown men described in the letter and the original attack on the Appellant, or to the attack on the Appellant's husband in 2002 by members of the Hausa. In view of this, and of the factors detailed above, I ascribe very little weight to this letter from the Appellant's son in establishing that it is the agents of harm identified in the Appellant's Refugee claim that are searching for her. [23] There is also no evidence that there is a serious possibility that attacks by the agents of harm identified by the Appellant will eventuate in the IFAs proposed by the RPD, given that the identity of the agents of harm is not known and that it is unclear what their motivation would be for continuing to seek out the Appellant in the proposed IFAs. [24] In the absence of this evidence and of submissions by the Appellant as to the means and motivation of these unknown persons to continue the attacks on her should she return to Nigeria, I agree with the RPD that the Appellant has provided insufficient evidence in support of the contention that the agents of harm have the requisite means and motivation to locate her. There is therefore also no credible evidence that she would need to live in hiding. Consequently, I find that the Appellant has not met the first prong of the test in Rasaratnam as regards these IFAs. Second Prong of the Test: Is Relocation to Abuja or Ibadan Unreasonable or Unduly Harsh? [25] As with the first prong of the test, the Appellants have the burden of providing sufficient evidence to establish that it is unduly harsh or unreasonable for them to relocate to any of the proposed IFAs. The threshold is high - it requires nothing less than the existence of conditions which would jeopardize the life and safety of the Appellant in travelling to or temporarily relocating to a safe area. [26] Counsel has submitted that the RPD erred in its assessment of the factors it considered when assessing whether the proposed IFAs would be unreasonable or unduly harsh for the Appellant. [27] The current National Documentation Package (NDP) for Nigeria provides information regarding the general viability of internal location. A document published by the United Kingdom Home office, which provides guidance to Home Office decision makers on handling particular types of persecution and human rights claims, notes as follows: 2.2.5 In general a person fearing a non-state actor is likely to be able to relocate to another part of Nigeria depending on the nature of the threat from the nonstate agent(s) and the individual circumstances of the person. However, relocation may be more difficult for single women and non-indigenes without access to support networks.13 [28] I have considered below the factors that are often used by the RPD and RAD when determining the issue of IFA in Nigeria. In what follows, in order to simplify my task, I have confined my analysis to the proposed IFAs of Abuja and Ibadan. Since, as explained below, I find that either of these IFAs would be unduly harsh nor unreasonable, it is unnecessary for me to examine the other IFAs proposed by the RPD. [29] I find, for the reasons set out below, that the Appellants have failed to establish that relocation to the IFAs of Abuja or Ibadan would be unduly harsh or unreasonable. Travel to the proposed IFAs [30] In analyzing the viability of a proposed IFA, consideration must be given to the Gender Guidelines, which states in part: "in determining the reasonableness of a woman's recourse to an internal flight alternative (IFA), decision-makers should consider the ability of women, because of their gender, to travel safely to the IFA and to stay there without facing undue hardship."14 The RPD did not raise the issue of travel to the proposed IFAs and whether it would be safe for the Appellant, and no submissions have been received from the Appellant on this issue. I find that the Federal Capital of Abuja has an international airport, and Ibadan has a domestic airport.15 The Appellant has not introduced any evidence that she is unable to travel safely to Abuja or Ibadan. In my independent assessment of the evidence before me, I find that the Appellant is able to safely travel to Abuja or Ibadan by aeroplane. Language [31] The Appellant testified that she speaks English and Yoruba. English is the official language in Nigeria, and a large percentage of the population speak Hausa, Yoruba, Igbo (Ibo), and Fulani in the major centres, in addition to over 500 indigenous languages.16 The documents note that in public administration. Moreover, the objective country conditions evidence shows that many persons in Ibadan speak Yoruba,17 and that the Yoruba comprise the largest minority group in Abuja.18 I therefore find that language does not pose a barrier for the Appellant in relocating to either Abuja or Ibadan. Education [32] The RPD noted that the Appellant has post-secondary education. Counsel has not made any specific comments about the Appellant's education. In my independent assessment, I find that the Appellant's Schedule A form19 and her oral testimony confirm that she has a two-year national diploma in business administration. I therefore find that the Appellant's education is a positive factor in her being able to relocate to either Ibadan or Abuja. Religion [33] The Appellant testified that she is a Christian, which is one of the major religions of Nigeria.20 I acknowledge that according to the country conditions documents, attacks by Boko Haram on Christians are "more likely to occur" in Abuja than in Lagos where there have been "isolated incidents" of violence based on religion, which are "relatively few."21 There is no indication in these country conditions documents of attacks on Christians in Ibadan. Moreover, the Appellant has not asserted that she faces any risks in Nigeria because of her religion. Accordingly, I find that this factor does not render relocation to these proposed IFAs unreasonable or unduly harsh for the Appellant. Employment [34] The Appellant stated in her oral testimony that employment would be an issue for her were she to live in the proposed IFAs "because men so dominate [sic] there". Counsel made reference at the RPD hearing to a Response to Information Request (RIR) regarding, among other issues, the difficulties single women face in obtaining employment. Counsel's Memorandum submits that the RPD erred in its assessment, because it failed to take account of the high rate of unemployment in Nigeria. [35] I agree with Counsel's submission that the documentary evidence indicates that there is a high rate of unemployment in Nigeria generally and that obtaining employment can be difficult for women. I have consulted the same RIR referenced by Counsel and the RPD,22 and I acknowledge that women may face greater difficulties in securing employment than men.. The country conditions documentation indicates that on average, females in Nigeria have only eight years of education.23 [36] In addition to her above-average level of education, the Appellant, as per her Schedule A form, has more than nine years of work experience in Nigeria. I also note the statement in the RIR that "it is easier for a woman to live alone without male support if she is educated"24 and has a high social status because she can use family connections. The Appellant, as per her testimony, was a businesswoman who owned her XXXX XXXX XXXX. The Appellant did not refer to her spouse in her testimony, and her Generic Application indicates her marriage lasted until 2012.25 As per the evidence, the Appellant was living in Nigeria as a single female from the time her marriage ended in 2012 until at least 2017. There is no evidence that she had difficulty supporting herself or heading her own household in Nigeria during that period. Her narrative states that she is "into" oil and gas marketing and services, maintenance of petroleum equipment (e.g. dispensing pumps, flow meters, storage tanks and installation of pumps and pipes).26 I find that, in view of her education and prior work experience, the Appellant has several advantages over the average Nigerian female in terms of finding employment. I also find she is in a superior position to the single females described in the RIR in terms of finding employment and sustaining herself economically. She has not advanced any arguments as to how circumstances have changed from the period when she lived in Nigeria previously, which would prevent her from sustaining herself if returned there. [37] For these reasons, I agree with the RPD that it is not objectively unreasonable or unduly harsh for the Appellant to secure employment in Abuja or Ibadan. Accommodation [38] Neither the RPD nor Counsel addressed the question of the Appellant securing accommodation in the proposed IFAs. I acknowledge that as per the above RIR, accommodation may be expensive and that single women may have difficulty securing it. However, the Appellant is not without family support. The Appellant's children as per her testimony are all adults, have post-secondary education, and have careers that they can pursue. To the extent that it may be advisable or necessary because of societal expectations in Nigeria for the Appellant to have male figures who apply for accommodation on her behalf, I note she has a son in Nigeria. Based on the evidence, the Appellant lived in Nigeria until recently and has provided no evidence that she was unable to secure accommodation in that country previously. Indeed, the Appellant testified that she was on the point of returning to Nigeria when her son in that country reported problems with unknown men. Again, the Appellant has not explained why conditions have changed such that she would be unable to secure accommodation now. In these circumstances, I find that while it is possible that the Appellant may initially experience difficulty in securing accommodation in the proposed IFAs, it is neither unreasonable nor unduly harsh to expect her to do so. Indigeneship [39] Although the evidence is mixed, it is clear that due to significant migration to large, urban cities, indigeneship is not a significant barrier to relocation in these cities. Item 13.1 provides information on point, which states: ...indigeneship status is less important in big cities such as Lagos, Abuja, and Port Harcourt than it is in other places, in terms of access to public jobs or ownership of land, because the indigene population in these areas has been "overwhelmed" by migrants to the cities. He explained, for example, that the establishment of the Federal Capital Territory pushed the indigenes of Abuja further from the "centre of influence." However, he also indicated that indigenous ethnic groups continue to dominate the market for land in Lagos, and that indigenes of the Niger Delta, including in Port Harcourt, have been demanding a greater allocation of jobs in the region's oil industry. Non-indigenes also face discrimination in the field of politics. Nevertheless, the Professor stated that, in other industries, they can generally find work where there is a demand for it [citations omitted].27 [40] The burden is on the Appellant to show that any discrimination that could be faced in Ibadan or Abuja on the basis of her ethnicity or non-indigeneship would rise to the level that it renders the proposed IFAs unreasonable or unduly harsh. The Appellant has not argued that indigeneship is a major barrier to her relocation to the proposed IFAs. I find, after considering the evidence before me, that this factor does not render the Appellant's relocation to the larger urban settings of Ibadan and Abuja unduly harsh nor unreasonable. Other issues [41] Although Counsel submits that the psychological impact of the Appellant "living in fear"28 of being located by her attackers in any part of Nigeria must be considered, I have already found that the Appellant will be safe from the agents of harm in the proposed IFAs. I do not accept that on an objective basis the Appellant will have to live in fear of the attackers in the proposed IFAs. Moreover, there is no psychological assessment or evidence to before me to support a finding that her trauma would rise to such a level that the IFA would be unreasonable or unduly harsh. The Appellant has also not alleged that there are any other circumstances within the proposed IFAs, such as general levels of violence or other factors, that would cause her significant psychological harm. [42] Additionally, I do not agree with Counsel's submission that the RPD failed to apply the appropriate principles of justice and understanding, or that the RPD was influenced by personal consideration that the Appellant may be an "undeserving case."29 I find that the RPD considered all the appropriate factors, and I see no indication of a reasonable apprehension of bias in how the RPD conducted its assessment, or that a reasonable person would conclude based on the evidence that the RPD somehow viewed the Appellant as not deserving full and careful consideration. [43] I have considered the Gender Guidelines and find that the RPD questioned the Appellant appropriately in her circumstances. I have found that she does have family support, including support from her son in Nigeria, and so I regard the risks that she will be subjected to physical violence, abuse, sexual abuse, or psychological abuse as being reduced in her case, such that there is not a serious possibility these will affect her in the proposed IFAs. [44] In my evaluation of the sum of the evidence, I find that it would not be unduly harsh or unreasonable for the Appellant to relocate to Ibadan or Abuja. [45] The issue of IFA is determinative of claims under both section 96 and section 97(1) of IRPA, and as a result of my conclusions on this subject, I find that the Appellant's claim fails. CONCLUSION [46] Pursuant to section 111(1)(a) of the IRPA,30 the RAD confirms the decision of the RPD that the Appellant is not a Convention refugee nor a person in need of protection. (signed) "Ron Liberman" Ron Liberman Original decision rendered on October 1, 2020 Reasons and decision amended on October 5, 2020 1 Immigration and Refugee Board of Canada, Guidelines Issued by the Chairperson Pursuant to Section 65(3) of the Immigration Act: Guideline 4 - Women Refugee Claimants Fearing Gender-Related Persecution, Effective date: 13 November 1996. 2 1951 Convention Relating to the Status of Refugees: Office of the United Nations High Commissioner for Refugees, "Handbook on Procedures and Criteria for Determining Refugee Status", under the 1951 Convention. 3 Immigration and Refugee Protection Act (IRPA), SC 2001, c.27, section 96 and section 97. 4 Huruglica v. Canada (Citizenship and Immigration), 2014 FC 799, [2014] 4 RCF 811. 5 Refugee Appeal Division Rules, SOR/2012-257, Rule 29: 6 Immigration and Refugee Protection Act (IRPA), S.C. 2001, c. 27, section 110(4). 7 Raza v. Canada (Minister of Citizenship and Immigration), 2007 FCA 385. 8 Canada (Minister of Citizenship and Immigration) v. Singh, 2016 FCA 96, [2016] 4 FCR 230. 9 Raza v. Canada (Minister of Citizenship and Immigration), 2007 FCA 385; Canada (Citizenship and Immigration) v. Singh, 2016 FCA 96, [2016] 4 FCR 230. 10 Rasaratnam v. Canada (Minister of Employment and Immigration) [1992] 1 FC 706 (FCA). 11 IRPA, section 96 and section 97. 12 Maldonado v. Canada (Minister of Employment and Immigration), [1980] 2 F.C. 302 (C.A.). 13 National Documentation Package (NDP) for Nigeria (November 29, 2019), item 1.17: Country Policy and Information Note. Nigeria: Trafficking of women. Version 1.0, May 2019. 14 Supra, at endnote 1. 15 NDP for Nigeria (April 30, 2019), item 1.23: EASO Country of Origin Information Report. Nigeria: Key socio-economic indicators, November 2018, at section 3.1. 16 NDP for Nigeria (April 30, 2019), item 1.6: Nigeria. The World Factbook, April 2019. 17 NDP for Nigeria (April 30, 2019) item 1.4: EASO Country of Origin Information Report: Nigeria. Country Focus, June 2017, at section 1.4. 18 NDP for Nigeria (April 30, 2019), item 1.15: Nigeria. L'aménagement linguistique dans le monde, July 2017. 19 Exhibit RPD-1, RPD Record, at p. 30. 20 Supra, at endnote 15. 21 NDP for Nigeria (April 30, 2019), item 12.5: Situation of Christians, including those living in northern cities, Lagos and Abuja; state protection (2011-October 2015), November 2015. 22 NDP for Nigeria (April 30, 2019), item 5.9: Whether women who head their own households, without male or family support, can obtain housing and employment in large northern cities, such as Kano, Maiduguri, and Kaduna, and southern cities, such as Lagos, Ibadan, Port Harcourt; government support services available to female-headed households, November 2012. 23 Supra, at endnote 15. 24 Exhibit P-2, Appellant's Record, at para. 9, at p. 7. 25 Exhibit RPD-1, RPD Record, at p. 25. 26 Exhibit RPD-1, RPD Record, Appellant's Basis of Claim form narrative, at p. 22. 27 NDP for Nigeria (April 30, 2019), item 13.1: Nigeria: Whether a member of an ethnic group can be identified by physical characteristics, manner of dress, or by any other means; obstacles faced when relocating to Abuja, Lagos or Port Harcourt, November 2012. 28 Exhibit P-2, Appellant's Record, Memorandum of Counsel, at p. 16, at para. 33. 29 Exhibit P-2, Appellant's Record, Memorandum of Counsel, at p. 18, at para. 50. 30 IRPA, section 111(1)(a). --------------- ------------------------------------------------------------ RAD File / Dossier de la SAR : VB9-05588 RAD.25.02 (January, 2020) 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 (January, 2020) Disponible en français