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Ontario Refugee and Immigration Law Guide 2024: Asylum Claims, IRPA, and Appeals

Refugee Convention 5 grounds, RPD 8-stage hearing process, sur place claims, RAD appeal, PRRA, H&C applications under IRPA s.25, 8 inadmissibility grounds, and Safe Third Country Agreement implications for Ontario immigration lawyers.

December 202416 min readAtticus Legal Team

Refugee and immigration law is among the most consequential areas of Ontario legal practice. Errors in refugee proceedings can result in refusal and return to a country where a client faces persecution, torture, or death. Ontario immigration lawyers must master the refugee determination process, the appeals available, and the alternative relief mechanisms when claims fail.

Canada's refugee system is governed by the Immigration and Refugee Protection Act (IRPA) and the Refugee Protection Division Rules. The Refugee Protection Division (RPD) and Refugee Appeal Division (RAD) are independent administrative tribunals that operate under the Immigration and Refugee Board of Canada (IRB).

This guide covers the five Convention grounds for refugee protection, the RPD hearing process, sur place claims, the RAD appeal and Federal Court judicial review, the PRRA, H&C applications, and the inadmissibility grounds Ontario immigration lawyers encounter most frequently.

The Five Refugee Convention Grounds Under IRPA

To qualify as a Convention refugee, a claimant must establish a well-founded fear of persecution based on one of five protected grounds. The fear must be both subjectively genuine and objectively reasonable given country conditions. State protection must be unavailable or inadequate.

Convention GroundDefinitionExamples
RacePersecution based on the claimant's racial origin or ethnicityEthnic minority persecuted by state or non-state actors; racial profiling by police; ethnically motivated violence
ReligionPersecution based on religious beliefs, practices, or identityConverts persecuted by family or state; religious minorities facing state oppression; apostasy charges
NationalityPersecution based on national origin, citizenship, or statelessnessStateless persons denied citizenship; persecution of minority nationalities; cross-border ethnic conflict
Membership in a particular social groupPersecution based on membership in a group sharing an immutable characteristic or fundamental identityLGBTQ+ persons; women fleeing gender-based violence; domestic violence victims; gang victimization (case-by-case)
Political opinionPersecution based on actual or perceived political viewsOpposition politicians; journalists; human rights activists; trade union leaders; perceived dissidents

Person in need of protection (IRPA s.97): In addition to Convention refugees, a person may be recognized as a "person in need of protection" if removal would subject them personally to a risk to their life or to risk of cruel and unusual treatment or punishment. This ground captures claimants who do not fit neatly into the Convention grounds but face serious individualized risk in their home country.

RPD Refugee Hearing Process: 8 Stages

1

Claim made at port of entry or inland

Eligibility determination within 3 working days (detained); 15 working days (others)

Claim can be made at a land border crossing, airport, or at an inland IRCC office

Third country nationals from the US subject to Safe Third Country Agreement (STCA) at official land crossings

2

Eligibility determination

Decision within 3 or 15 working days depending on detention status

CBSA or IRCC determines whether the claimant is eligible to make a refugee claim in Canada

Ineligible if already recognized as refugee in another country, previously rejected in Canada, or subject to extradition

3

Referral to RPD

Hearing typically scheduled within 45-60 days for CLAM system; longer in practice

Eligible claimants are referred to the Refugee Protection Division; assigned a hearing date

Claimant must complete Basis of Claim form within 15 days of referral (inland) or at time of claim (border)

4

Basis of Claim preparation

15 days for inland claims; at time of claim for border claims

Claimant submits detailed written narrative of persecution feared; this is the foundation of the claim

Critical document; inconsistencies between BOC and testimony are a primary credibility concern

5

Document disclosure

Documents must be filed at least 10 days before the hearing

Both parties exchange documents; claimant provides country condition evidence and personal documents

Late disclosure requires RPD leave; failure to disclose can result in inadmissibility of evidence

6

RPD hearing

Typically 90 minutes to 3 hours; can be longer for complex claims

Hearing before a member of the Refugee Protection Division; claimant testifies; member questions

Claimant can request an interpreter; refugee claimant has right to counsel; Crown counsel (IRCC) may intervene

7

RPD decision

Decision typically within 90 days of hearing; shorter for straightforward claims

Member issues decision to accept or reject the claim with written reasons

Accepted claims result in Convention refugee or person in need of protection status; rejected claims trigger appeal rights

8

RAD appeal or Federal Court review

RAD appeal: 15 days to file; Federal Court judicial review: 15 days to file leave application

Rejected claimants may appeal to the Refugee Appeal Division or seek judicial review of RPD decision

RAD cannot hear new evidence except in limited circumstances; Federal Court reviews only for error of law or fact

Inadmissibility Grounds Under IRPA

Even where a claimant has a legitimate refugee claim, they may be inadmissible to Canada on independent grounds. Inadmissibility can result in exclusion from the Convention refugee definition (Article 1F exclusion clause) or removal despite refugee status in serious criminality cases.

GroundBasisIRPA
SecurityEspionage, subversion of democratic government, terrorism, or being a member of a terrorist organizations. 34
Human or international rights violationsWar crimes, crimes against humanity, being a senior official in a government that engaged in tortures. 35
Serious criminalityConviction in Canada of an offence punishable by maximum 10 years or more, for which sentence of 6 months or more was imposeds. 36(1)
Criminality (PR and temporary residents)Conviction for an indictable offence or two summary offencess. 36(2)
Organized criminalityMember of a criminal organization; engaging or having engaged in criminal organization activitys. 37
Health groundsCondition that is a danger to public health or public safety, or that would cause excessive demand on health servicess. 38
Financial reasonsUnable or unwilling to support oneself or dependantss. 39
MisrepresentationMisrepresenting or withholding material facts in an immigration application; organized fraud schemess. 40

Frequently Asked Questions

What is the refugee definition under Canadian law?

Under the Immigration and Refugee Protection Act (IRPA) and the 1951 Refugee Convention, a Convention refugee is a person who has a well-founded fear of persecution based on one of five grounds: race, religion, nationality, membership in a particular social group, or political opinion. The fear must be both subjective (the claimant genuinely fears persecution) and objective (there is a reasonable basis for the fear given country conditions). The claimant must also be outside their country of nationality or habitual residence.

What happens if the Refugee Protection Division rejects a refugee claim?

If the Refugee Protection Division (RPD) rejects a refugee claim, the claimant generally has 15 days to file an appeal to the Refugee Appeal Division (RAD). The RAD may affirm, set aside, or substitute the RPD's decision. If the RAD also rejects the claim, the claimant may apply for a Pre-Removal Risk Assessment (PRRA) and/or make a Humanitarian and Compassionate (H&C) application. Judicial review to the Federal Court is available from RAD decisions within 15 days.

What is a sur place refugee claim in Canada?

A sur place claim is a refugee claim based on events that occurred after the claimant left their home country. The risk of persecution arises not from conditions that existed when the claimant left, but from changed country conditions or the claimant's own activities in Canada (such as political activism, converting religion, or publicly opposing the home government). Sur place claims are fully recognized under Canadian law but are subject to careful scrutiny — particularly where the claimant's activities in Canada appear designed to manufacture a refugee claim.

What is a humanitarian and compassionate application in Canada?

A humanitarian and compassionate (H&C) application under IRPA s.25 allows a person who is otherwise inadmissible or ineligible to remain in Canada to request permanent residence on the basis of humanitarian and compassionate considerations. The decision-maker weighs factors including establishment in Canada, best interests of any children directly affected, family ties to Canada, country conditions, and hardship. H&C applications are decided by IRCC officers and are not a refugee determination — a failed refugee claim does not bar an H&C application.

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