In Lukács v. Canada (Citizenship and Immigration) (Fed CA, 2023) the Federal Court of Appeal considered an appeal of an IRPA s.87 ['Application for non-disclosure — judicial review and appeal'] order made at the Federal Court in the context of a JR challenging the entry into Canada of people travelling from Hungary. The order was with respect to 'confidential information' that was "inadvertently disclosed", and it's effect was to "enjoin() Dr. Gabor Lukács and others, from retaining, disclosing or disseminating certain confidential information". In this quote the court considered, and dismissed, the argument that a 'mandatory order' could not be made against a non-party:
 Dr. Lukács also argued that a mandatory order could not be made against a non-party. Since he and others were not parties to the motion for injunctive relief, Dr. Lukács argues that the Court had no jurisdiction to make a mandatory order against them. This argument is without merit. Equitable relief in the form of an injunction may be issued against non-parties where it appears to the court to be just or convenient that the order should be made (Google Inc. v. Equustek Solutions Inc., 2017 SCC 34,  1 S.C.R. 824 at para. 28).
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