In Bryzzhev v. Canada (Attorney General) (Fed CA, 2025) the Federal Court of Appeal dismissed an appeal from a JR, here from the "decision of Passport Canada to close his passport application on the ground that the appellant refused to submit a new application with the name of a new guarantor".
Here the court considers (and dismisses) an argument that "waiting hours in phone cues and, generally, unsatisfactory customer service" are bureaucratic inconveniences amounting to "the level of Charter breaches or of international human rights violations":
[12] .... I agree with the Federal Court that the requirements to obtain a passport, waiting hours in phone cues and, generally, unsatisfactory customer service are inconveniences that do not rise to the level of Charter breaches or of international human rights violations, assuming these rights are part of Canadian law. This is certainly not cruel and unusual treatment or punishment, as contended by the appellant. To rise to the level of cruel and unusual treatment or punishment, the impugned state action must be so excessive as to outrage the standards of decency and human dignity. Although the inconveniences described by the appellant may have been annoying, they do not amount to the type of treatment that engages Charter protection.
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