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Citizenship - Passport. Bryzzhev v. Canada (Attorney General)
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 commented on the purpose of the "passport application and issuing process" and it's guarantor requirement:[9] .... Maintaining the integrity of the passport application and issuing process is clearly in the public interest for a number of reasons, namely (i) preventing and redressing the misuse of passports for domestic and international security purposes; (ii) meeting foreign governments’ expectations regarding the reliability of Canadian travel documents; and (iii) maintaining the good reputation of the Canadian passport (Canada (Attorney General) v. Dias, 2014 FCA 195 at para. 9; Alsaloussi v. Canada (Attorney General), 2020 FC 364 at paras. 24, 58, 61 and 66; Abaida v. Canada (Attorney General), 2018 FC 490 at para. 4). This is very much part of the institutional context in which the impugned decision was made.
[10] Here, Passport Canada found that the applicant had attempted to impersonate his guarantor. This is a serious matter that undermines the integrity of the passport issuance process. In such circumstances, Passport Canada was entitled, pursuant to paragraph 8(1) of the Canadian Passport Order, SI/81-86, to request from the appellant "“further information, material, or declarations respecting any matter relating to the issue of the passport”". .... . Bryzzhev v. Canada (Attorney General)
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 briefly considered a Charter s.6 ['mobility rights'] passport issue:[12] Further, I see no merit whatsoever to the appellant’s constitutional and international human rights claims. With respect to the mobility rights guaranteed by section 6 of the Charter, it is trite that these rights are only engaged where the passport applicant meets the requisite conditions to warrant the issuance of a passport (Volkov v. Canada (Attorney General), 2015 FC 41, at para. 16). This is not the case here.
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