c. Article 16(3) In considering Article 16(3), research conducted for this report did not indicate whether stateless persons habitually resident in Canada were treated any differently than Canadian citizens in accessing courts, security for costs matters and legal assistance in other State Parties to the 1954 Convention. III. Assessment While it is not clear what permit or status allows a foreign national or a stateless persons to be considered “habitually resident” for the purposes of Article 16, it appears that the Canadian legal framework requires some form of residence in order to have access to courts in Canada. If a stateless person is resident in Canada or a particular province, they appear to be in the same position as Canadian nationals. Therefore, based on a review of case law, court rules of procedure, and the provision of legal aid in Alberta, British Columbia, Ontario and Quebec, the Canadian legal framework appears to be compatible with Article 16 of the 1954 Convention. IV. Recommendations 10) In support of Recommendation #5, further research should examine whether stateless persons have difficulty accessing legal assistance for immigration matters due to merit assessment criteria. CHAPTER III: GAINFUL EMPLOYMENT ARTICLE 17: WAGE-EARNING EMPLOYMENT 1. The Contracting States shall accord to stateless persons lawfully staying in their territory treatment as favourable as possible and, in any event, not less favourable that that accorded to aliens generally in the same circumstances, as regards the right to engage in wage-earning employment. 2. The Contracting States shall give sympathetic consideration to assimilating the rights of all stateless persons with regard to wage-earning employment to those of nationals, and in particular of those stateless persons who have entered their territory pursuant to programmes of labour recruitment or under immigration schemes. I. Background & Commentary The 1954 Convention does not define “wage-earning employment”, but the Commentary explains that it “should be taken in its broadest sense.”204 It is to include every person having 204 Robinson Commentary to the 1954 Convention, supra note 11 at 39. 40