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Abuse of Process - Administrative

The Supreme Court of Canada, in Blencoe (2000) and Abrametz (2022), has held that abuse of process in the administrative context "is a question of procedural fairness". As such, I link this present section in the 'procedural fairness' section as well.

. Law Society of Saskatchewan v. Abrametz

In Law Society of Saskatchewan v. Abrametz (SCC, 2022) the Supreme Court of Canada reviewed two forms in which administrative delay may constitute abuse of process, one involving 'hearing prejudice delay' (eg. evidentiary degradation) and the other not (as in 'inordinate delay': para 43). At para 44, 74-100 the court reviews the remedies that are available to respond to delay. The difference between criminal delay under Charter 11(b) and administrative delay are set out in paras 45-49:
(3) Abuse of Process in Administrative Proceedings

[38] In administrative proceedings, abuse of process is a question of procedural fairness: Blencoe, at paras. 105-7 and 121; G. Régimbald, Canadian Administrative Law (3rd ed. 2021), at pp. 344-350; P. Garant, with P. Garant and J. Garant, Droit administratif (7th ed. 2017), at pp. 766-67). This Court dealt with abuse of process as it relates to administrative delay in Blencoe. Our Court recognized that decision makers have, as a corollary to their duty to act fairly, the power to assess allegedly abusive delay.

[39] Mr. Blencoe, a former British Columbia Cabinet Minister, was accused by several women of sexual harassment. They filed complaints with the then British Columbia Council of Human Rights. Hearings were scheduled more than 30 months after the initial complaints were filed. Mr. Blencoe applied to have the proceedings stayed on the basis of abuse of process. While this Court declined to do so, it described circumstances when a stay could be ordered.

[40] The Court explained two ways in which delay may constitute an abuse of process.

[41] The first concerns hearing fairness. The fairness of a hearing can be compromised where delay impairs a party’s ability to answer the complaint against them, such as when memories have faded, essential witnesses are unavailable or evidence has been lost: Blencoe, at para. 102; D. J. M. Brown and J. M. Evans, with the assistance of D. Fairlie, Judicial Review of Administrative Action in Canada (loose-leaf), at § 9:57.

[42] This is not what is in issue in this appeal. Rather, the Court is concerned with a second category of abuse of process. Even when there is no prejudice to hearing fairness, an abuse of process may occur if significant prejudice has come about due to inordinate delay: Blencoe, at paras. 122 and 132.

[43] Blencoe sets out a three-step test to determine whether delay that does not affect hearing fairness nonetheless amounts to an abuse of process. First, the delay must be inordinate. Second, the delay must have directly caused significant prejudice. When these two requirements are met, courts or tribunals will proceed to a final assessment of whether the delay amounts to an abuse of process. Delay will amount to an abuse of process if it is manifestly unfair to a party or in some other way brings the administration of justice into disrepute: Behn, at paras. 40-41.

[44] The minority reasons in Blencoe concluded that there was an abuse of process, although the appropriate remedy was not a stay but rather an order for an expedited hearing and costs. In my view, the two sets of reasons in Blencoe can be read as complementing each other and expressing a coherent set of principles. The majority reasons set a higher threshold only for an abuse of process requiring a stay, and accepted that lesser remedies continue to be available where a stay is not warranted. With respect to when a stay of proceedings is warranted, the minority reasons recognized that a threshold of “shocking abuse” is necessary to justify a stay of proceedings (para. 155). Moreover, the minority reasons set a lower threshold for an abuse of process which might call for a lesser remedy, such as an order for an expedited hearing or costs.
. Blencoe v. British Columbia (Human Rights Commission)

In Blencoe v. British Columbia (Human Rights Commission) (SCC, 2000) the Supreme Court of Canada considered procedural delay in administrative proceedings, here in the context of an HRC respondents judicial review seeking a stay of the complaint. Unfortunately, the court make little reference to delay from the complainant's perspective. The case is useful to locate administrative delay within fairness and abuse of process doctrine, where - although abuse of process may extend to other than hearing prejudice - some prejudice is nonetheless required before the abuse of process becomes actionable (eg. justice disrepute: para 115):
101 In my view, there are appropriate remedies available in the administrative law context to deal with state-caused delay in human rights proceedings. However, delay, without more, will not warrant a stay of proceedings as an abuse of process at common law. Staying proceedings for the mere passage of time would be tantamount to imposing a judicially created limitation period (see: R. v. L. (W.K.), 1991 CanLII 54 (SCC), [1991] 1 S.C.R. 1091, at p. 1100; Akthar v. Canada (Minister of Employment and Immigration), [1991] 3 F.C. 32 (C.A.). In the administrative law context, there must be proof of significant prejudice which results from an unacceptable delay.

102 There is no doubt that the principles of natural justice and the duty of fairness are part of every administrative proceeding. Where delay impairs a party’s ability to answer the complaint against him or her, because, for example, memories have faded, essential witnesses have died or are unavailable, or evidence has been lost, then administrative delay may be invoked to impugn the validity of the administrative proceedings and provide a remedy (D. J. M. Brown and J. M. Evans, Judicial Review of Administrative Action in Canada (loose-leaf), at p. 9-67; W. Wade and C. Forsyth, Administrative Law (7th ed. 1994), at pp. 435-36). It is thus accepted that the principles of natural justice and the duty of fairness include the right to a fair hearing and that undue delay in the processing of an administrative proceeding that impairs the fairness of the hearing can be remedied (see, for example, J. M. Evans, H. N. Janisch and D. J. Mullan, Administrative Law: Cases, Text, and Materials (4th ed. 1995), at p. 256; Wade and Forsyth, supra, at pp. 435-36; Nisbett, supra, at p. 756; Canadian Airlines, supra; Ford Motor Co. of Canada v. Ontario (Human Rights Commission) (1995), 1995 CanLII 7431 (ON SC), 24 C.H.R.R. D/464 (Ont. Div. Ct.); Freedman v. College of Physicians & Surgeons (New Brunswick) (1996), 1996 CanLII 4828 (NB QB), 41 Admin. L.R. (2d) 196 (N.B.Q.B.)).

...

104 ... The question which must be addressed is therefore whether the delay in this case could amount to a denial of natural justice or an abuse of process even where the respondent has not been prejudiced in an evidentiary sense.

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106 Throughout the authorities in this area, terms such as “natural justice”, “procedural fairness”, “abuse of process”, and “abuse of discretion” are employed. In Martineau, at p. 629, Dickson J. (writing for three judges, while all nine concurred in the result), stated that “the drawing of a distinction between a duty to act fairly, and a duty to act in accordance with the rules of natural justice, yields an unwieldy conceptual framework”. With regard to these terms, I would adopt the following words of Sherstobitoff J.A. of the Saskatchewan Court of Appeal in Misra v. College of Physicians & Surgeons of Saskatchewan (1988), 1988 CanLII 211 (SK CA), 52 D.L.R. (4th) 477, at p. 490:
There are two common denominators in each of the terms. The first is the impossibility of precise definition because of their breadth and the wide array of circumstances which may bring them into play. The other is the concept of “fairness” or “fair play”. They clearly overlap. Unreasonable delay is a possible basis upon which to raise any of them.
...

108 In cases where the Charter was held not to apply, most courts and tribunals did not go further to decide whether the stress and stigma resulting from an unacceptable delay were so significant as to amount to an abuse of process. On the other hand, where courts did go further, they most often adopted a narrow approach to the principles of natural justice. For example, in Nisbett, supra, the Manitoba Court of Appeal concluded that delay may amount to an abuse of process that the law will remedy only where “on the record there has been demonstrated evidence of prejudice of sufficient magnitude to impact on the fairness of the hearing” (p. 757). In Canadian Airlines, supra, the Federal Court of Appeal followed Nisbett, concluding that the prejudice must be such “as to deprive a party of his right to a full and complete defence” (p. 641). In the case at bar, Lowry J. for the British Columbia Supreme Court, found that unless there was prejudice to hearing fairness, the type of personal hardship and psychological prejudice suffered by Mr. Blencoe could not give rise to a breach of natural justice (at para. 31):
... it cannot be said that the personal hardship Mr. Blencoe has suffered, albeit protracted by the time the administrative process has taken, gives rise to any Charter considerations. To my mind, it then becomes difficult to see how it can nonetheless be said to be a prejudice giving rise to a denial of natural justice. If it were, there would have been no need for the Kodellas court to resort to section 7 of the Charter. And, having rejected the applicability of section 7, the Nisbett court would have been bound to consider whether the personal hardship in that case constituted a prejudice that supported the prerogative relief sought.
109 However, courts and tribunals have also referred to other types of prejudice than trial fairness, holding that, where a commission or tribunal has abused its process to the detriment of an individual, a court has the discretion to grant a remedy. For example, in Stefani v. College of Dental Surgeons (British Columbia) (1996), 1996 CanLII 877 (BC SC), 44 Admin. L.R. (2d) 122 (B.C.S.C.), a variety of effects on the petitioner were examined, including a cloud over his professional reputation resulting from a delay of two years and three months between the receipt of the complaint and the inspection, and an additional six- or seven-month delay which followed. However, the delay in that case had also resulted in an inability for the petitioner to have a fair hearing.

...

115 I would be prepared to recognize that unacceptable delay may amount to an abuse of process in certain circumstances even where the fairness of the hearing has not been compromised. Where inordinate delay has directly caused significant psychological harm to a person, or attached a stigma to a person’s reputation, such that the human rights system would be brought into disrepute, such prejudice may be sufficient to constitute an abuse of process. The doctrine of abuse of process is not limited to acts giving rise to an unfair hearing; there may be cases of abuse of process for other than evidentiary reasons brought about by delay. It must however be emphasized that few lengthy delays will meet this threshold. I caution that in cases where there is no prejudice to hearing fairness, the delay must be clearly unacceptable and have directly caused a significant prejudice to amount to an abuse of process. It must be a delay that would, in the circumstances of the case, bring the human rights system into disrepute. The difficult question before us is in deciding what is an “unacceptable delay” that amounts to an abuse of process.

(c) Abuse of Process – Principles

116 The respondent’s case is that there has been an unacceptable delay in the administrative process which has caused him to be prejudiced by the stigma attached to the two Complaints to an extent that justifies the process being terminated now. Abuse of process is a common law principle invoked principally to stay proceedings where to allow them to continue would be oppressive. As stated by Brown and Evans, supra, at pp. 9-71 and 9-72:
The stringency of the requirements for showing that delay constitutes a breach of fairness would seem to be due, at least in part, to the drastic nature of the only appropriate remedy. Unlike other instances of procedural unfairness where it is open to a court to remit the matter for redetermination in a procedurally fair manner, the remedy for undue delay will usually be to prevent the tribunal from exercising its legislative authority, either by prohibiting it from proceeding with the hearing, or by quashing the resulting decision. [Emphasis added.]
117 In the context of a breach of s. 11(b) of the Charter, a stay has been found to constitute the only possible remedy (R. v. Askov, 1990 CanLII 45 (SCC), [1990] 2 S.C.R. 1199). The respondent asked for the same remedy in his administrative law proceedings before Lowry J. There is, however, no support for the notion that a stay is the only remedy available in administrative law proceedings. A stay accords very little importance to the interest of implementing the Human Rights Code and giving effect to the complainants’ rights to have their cases heard. Other remedies are available for abuse of process. Where a respondent asks for a stay, he or she will have to bear a heavy burden. The discussion that follows often links abuse of process and the remedy of a stay because the stay, as I have said, is the only applicable remedy in the context of a s. 11(b) application. Nevertheless, I wish to underline that my inquiry here is directed only at the determination of the existence of an abuse of process on the facts of this case.

118 In R. v. Jewitt, 1985 CanLII 47 (SCC), [1985] 2 S.C.R. 128, this Court unanimously affirmed that the doctrine of abuse of process was available in criminal proceedings. In so doing, and as professed by L’Heureux‑Dubé J. in R. v. Power, 1994 CanLII 126 (SCC), [1994] 1 S.C.R. 601, at p. 613, the Court borrowed the comments of Dubin J.A. in R. v. Young (1984), 1984 CanLII 2145 (ON CA), 40 C.R. (3d) 289 (Ont. C.A.), in describing the abuse of process doctrine, stating that a stay of proceedings should be granted where “compelling an accused to stand trial would violate those fundamental principles of justice which underlie the community’s sense of fair play and decency” or where the proceedings are “oppressive or vexatious”. The Court also adopted the Ontario Court of Appeal’s warning in Young that this is a power which can be exercised only in the “clearest of cases” (p. 614). This was reiterated on many occasions by this Court (see, for example, R. v. Potvin, 1993 CanLII 113 (SCC), [1993] 2 S.C.R. 880; R. v. Scott, 1990 CanLII 27 (SCC), [1990] 3 S.C.R. 979; Power, supra).

119 In R. v. Conway, 1989 CanLII 66 (SCC), [1989] 1 S.C.R. 1659, at p. 1667, L’Heureux‑Dubé J. explained the underlying purpose of the doctrine of abuse of process as follows:
Under the doctrine of abuse of process, the unfair or oppressive treatment of an appellant disentitles the Crown to carry on with the prosecution of the charge. The prosecution is set aside, not on the merits (see Jewitt, supra, at p. 148), but because it is tainted to such a degree that to allow it to proceed would tarnish the integrity of the court. The doctrine is one of the safeguards designed to ensure “that the repression of crime through the conviction of the guilty is done in a way which reflects our fundamental values as a society” (Rothman v. The Queen, 1981 CanLII 23 (SCC), [1981] 1 S.C.R. 640, at p. 689, per Lamer J.) It acknowledges that courts must have the respect and support of the community in order that the administration of criminal justice may properly fulfil its function. Consequently, where the affront to fair play and decency is disproportionate to the societal interest in the effective prosecution of criminal cases, then the administration of justice is best served by staying the proceedings. [Emphasis added.]
120 In order to find an abuse of process, the court must be satisfied that, “the damage to the public interest in the fairness of the administrative process should the proceeding go ahead would exceed the harm to the public interest in the enforcement of the legislation if the proceedings were halted” (Brown and Evans, supra, at p. 9-68). According to L’Heureux‑Dubé J. in Power, supra, at p. 616, “abuse of process” has been characterized in the jurisprudence as a process tainted to such a degree that it amounts to one of the clearest of cases. In my opinion, this would apply equally to abuse of process in administrative proceedings. For there to be abuse of process, the proceedings must, in the words of L’Heureux‑Dubé J., be “unfair to the point that they are contrary to the interests of justice” (p. 616). “Cases of this nature will be extremely rare” (Power, supra, at p. 616). In the administrative context, there may be abuse of process where conduct is equally oppressive.

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(d) Was the Delay Unacceptable?

121 To constitute a breach of the duty of fairness, the delay must have been unreasonable or inordinate (Brown and Evans, supra, at p. 9-68). There is no abuse of process by delay per se. The respondent must demonstrate that the delay was unacceptable to the point of being so oppressive as to taint the proceedings. While I am prepared to accept that the stress and stigma resulting from an inordinate delay may contribute to an abuse of process, I am not convinced that the delay in this case was “inordinate”.

122 The determination of whether a delay has become inordinate depends on the nature of the case and its complexity, the facts and issues, the purpose and nature of the proceedings, whether the respondent contributed to the delay or waived the delay, and other circumstances of the case. As previously mentioned, the determination of whether a delay is inordinate is not based on the length of the delay alone, but on contextual factors, including the nature of the various rights at stake in the proceedings, in the attempt to determine whether the community’s sense of fairness would be offended by the delay.

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129 In Kodellas, supra, the Saskatchewan Court of Appeal held that the determination of whether the delay is unreasonable is, in part, a comparative one whereby one can compare the length of delay in the case at bar with the length of time normally taken for processing in the same jurisdiction and in other jurisdictions in Canada. While this factor has limited weight, I would note that in this regard, on average, it takes the Canadian Human Rights Commission 27 months to resolve a complaint (J. Simpson, “Human Rights Commission Mill Grinds Slowly”, The Globe & Mail (October 1, 1998), p. A18, as quoted in R. E. Hawkins, “Reputational Review III: Delay, Disrepute and Human Rights Commissions” (2000), 25 Queen’s L.J. 599, at p. 600). In Ontario, the average length of complaints, according to the Annual Report 1997-1998 of the Ontario Human Rights Commission (1998), at p. 24, is 19.9 months. The respondent’s counsel at the oral hearing quoted a report of the British Columbia Ministry where the average time to get to a hearing in British Columbia is three years.

130 The delay in the case at bar should be compared to that in analogous cases. In Nisbett, the sexual harassment complaint had been outstanding for approximately three years. In Canadian Airlines, there was a 50-month delay between the filing of the complaint and the appointment of an investigator. In Stefani, there was a delay of two years and three months between the complaint and the inspection and an additional six- or seven-month delay which followed. In Brown, a three-year period had elapsed prior to serving the petitioner with notice of the inquiry. In Misra, there was a five-year delay during which time Misra was suspended from the practice of medicine. Finally, in Ratzlaff, it had been seven years before the physician received a hearing notice.

131 A review of the facts in this case demonstrates that, unlike the aforementioned cases where there was complete inactivity for extremely lengthy periods, the communication between the parties in the case at bar was ongoing. While Lowry J. acknowledged the five-month delay of inactivity, on balance, he found no unacceptable delay and considered the time that elapsed to be nothing more “than the time required to process complaints of this kind given the limitations imposed by the resources available” (para. 47). Lowry J. concluded as follows (at para. 49):
In my view, it cannot be said that the Commission or the Tribunal have acted unfairly toward Mr. Blencoe. They have caused neither an unacceptable delay in the process nor a prejudice to him whereby fairness of the hearings scheduled to be conducted next month have been compromised. There has been no denial of natural justice and, accordingly, Mr. Blencoe’s petition for judicial review cannot succeed.
132 As expressed by Salmon L.J. in Allen v. Sir Alfred McAlpine & Sons, Ltd., [1968] 1 All E.R. 543 (C.A.), at p. 561, “it should not be too difficult to recognise inordinate delay when it occurs”. In my opinion, the five-month inexplicable delay or even the 24-month period from the filing of the Complaints to the referral to the Tribunal was not so inordinate or inexcusable as to amount to an abuse of process. Taking into account the ongoing communication between the parties, the delay in this case does not strike me as one that would offend the community’s sense of decency and fairness. While I would not presume to fix a specified period for a reasonable delay, I am satisfied that the delay in this case was not so inordinate as to amount to an abuse of process.

133 As noted in the discussion pertaining to the application of s. 7 of the Charter (paras. 59 to 72), I am also concerned with the causal connection in this case. There must be more than merely a lengthy delay for an abuse of process; the delay must have caused actual prejudice of such magnitude that the public’s sense of decency and fairness is affected. While Mr. Blencoe and his family have suffered obvious prejudice since the various sexual harassment allegations against him were made public, as explained above, I am not convinced that such prejudice can be said to result directly from the delay in the human rights proceedings. As in the Charter analysis above, I have simply assumed without deciding, for the purpose of my analysis, that the delay caused by the Commission was a contributory cause of the respondent’s prejudice.
. Nagy v. University of Ottawa

In Nagy v. University of Ottawa (Div Court, 2022) the Divisional Court considered the remedial jurisdiction of a tribunal where it finds abuse of process:
[12] The Tribunal has a statutory right to stay an application that it considers to be an abuse of process: Statutory Powers Procedure Act, s. 23(1). The definition of abuse of process is set out by the Supreme Court in Toronto (City) v. C.U.P.E., Local 79, 2003 SCC 63; [2003] 3 S.C.R. 77. In that case, Arbour J. said (at p. 101):
35 Judges have an inherent and residual discretion to prevent an abuse of the court's process. This concept of abuse of process was described at common law as proceedings "unfair to the point that they are contrary to the interest of justice" (R. v. Power, 1994 CanLII 126 (SCC), [1994] 1 S.C.R. 601, at p. 616), and as "oppressive treatment" (R. v. Conway, 1989 CanLII 66 (SCC), [1989] 1 S.C.R. 1659, at p. 1667). McLachlin J. (as she then was) expressed it this way in R. v. Scott, 1990 CanLII 27 (SCC), [1990] 3 S.C.R. 979, at p. 1007:
... abuse of process may be established where: (1) the proceedings are oppressive or vexatious; and (2) violate the fundamental principles of justice underlying the community's sense of fair play and decency. The concepts of [page102] oppressiveness and vexatiousness underline the interest of the accused in a fair trial. But the doctrine evokes as well the public interest in a fair and just trial process and the proper administration of justice.
36 The doctrine of abuse of process is used in a variety of legal contexts. The unfair or oppressive treatment of an accused may disentitle the Crown to carry on with the prosecution of a charge: Conway, supra, at p. 1667. In Blencoe v. British Columbia (Human Rights Commission), [2000] 2 S.C.R. 307, 2000 SCC 44 (S.C.C.), this Court held that unreasonable delay causing serious prejudice could amount to an abuse of process. When the Canadian Charter of Rights and Freedoms applies, the common law doctrine of abuse of process is subsumed into the principles of the Charter such that there is often overlap between abuse of process and constitutional remedies (R. v. O'Connor, 1995 CanLII 51 (SCC), [1995] 4 S.C.R. 411 (S.C.C.)). The doctrine nonetheless continues to have application as a non-Charter remedy: United States v. Shulman, [2001] 1 S.C.R. 616, 2001 SCC 21 (S.C.C.), at para. 33.

37 In the context that interests us here, the doctrine of abuse of process engages "the inherent power of the court to prevent the misuse of its procedure, in a way that would ...bring the administration of justice into disrepute" (Canam Enterprises Inc. v. Coles (2000), 2000 CanLII 8514 (ON CA), 51 O.R. (3d) 481 (C.A.) at para. 55, per Goudge J.A., dissenting (approved [2002] 3 S.C.R. 307, 2002 SCC 63 (S.C.C.)). Goudge J.A. expanded on that concept in the following terms, at paras. 55-56:
The doctrine of abuse of process engages the inherent power of the court to prevent the misuse of its procedure, in a way that would be manifestly unfair to a party to the litigation before it or would in some other way bring the administration of justice into disrepute. It is a flexible doctrine unencumbered by the specific requirements of concepts such as issue estoppel. See House of Spring Gardens Ltd. v. Waite, [1990] 3 W.L.R. 347 at p. 358, [1990] 2 All E.R. 990 (C.A.).

One circumstance in which abuse of process has been applied is where the litigation before the court is found to be in essence an attempt to relitigate a claim which the court has already determined. [Emphasis added by Arbour J.]
[13] Applying the doctrine of abuse of process engages the tribunal’s power to control its own process. It is context-based and fact-driven and involves the exercise of discretion. In my view, the legal system as a whole does not require a single determinate answer as to when a proceeding before a tribunal should be stayed as an abuse of process, particularly in the case of the Human Rights Tribunal, whose decisions are intended by the legislature to be final in most circumstances. In my view, the Tribunal is meant to be the judge of the use of its own process. Accordingly, the Tribunal’s decision should be reviewed on a deferential standard.
. Bagherian v. Aviva Insurance Company

In Bagherian v. Aviva Insurance Company (Div Ct, 2022) the Divisional Court held that an abuse of process had been made-out where a SABS applicant was unco-operative with required medical examinations:
[14] Rule 3.4(a) of the Tribunal’s rules provides that the Tribunal can dismiss an application without a hearing if the proceeding is frivolous, vexatious or commenced in bad faith. The Tribunal stated in the reconsideration decision that while the appellant had not commenced the proceeding in bad faith, he had repeatedly demonstrated a pattern of bad faith conduct because of his repeated failure to submit to psychologists’ examinations.

[15] There was ample evidence in the record to support this conclusion. Pursuant to s. 44(1) of the Schedule the appellant had a positive obligation to attend assessments requested by the insurer that are “reasonably necessary”. Moreover, his failure to cooperate in obtaining an assessment had interfered with the respondent’s ability to participate in the process before the Tribunal. As well, he had caused delay in the timely determination of the matter before the Tribunal.

[16] The appellant has not demonstrated that the Tribunal made any error of law. First, the Tribunal had the legal authority to dismiss his application pursuant to Rule 3.4(a), as well as s. 23(1) of the SPPA. That section provides that “a tribunal may make such orders or give such directions in proceedings before it as it considers proper to prevent abuse of its processes.” The record before the Tribunal amply supported the conclusion that the appellant’s conduct was an abuse of its process. He was given multiple opportunities to complete an IE with a psychologist and each time, he raised issues with the consent form, threatened to report the psychologist to the College, and threatened civil action. The Tribunal concluded that his conduct was frustrating the IE process.



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