a removal order from Canada include: security grounds, human or international rights violations, serious criminality, criminality, organized criminality, health grounds, financial reasons, misrepresentation, failure to comply with conditions established under the IRPA, and being an accompanying family member of an inadmissible foreign national.487 Whether a foreign national receives an inadmissibility hearing before the Immigration Division or is issued a removal order after an interview with a Minister’s delegate depends on the inadmissibility ground for which the foreign national is facing removal.488 Generally, when a foreign national receives a full hearing at the Immigration Division, there are “reasonable grounds to believe” that the foreign national is inadmissible on the grounds of security, human or international rights violations, serious criminality and organized crime.489 These grounds are most likely to include matters of “national security and public order” and this appears to be in compliance with Article 31(1) and 31(2). However, the IRPA also permits the issuance of a removal order to a foreign national when they are inadmissible on medical, financial reasons, misrepresentation, failure to comply with obligations under the IRPA (ie. conditions on a permit), or accompanying an inadmissible family member. Some of these inadmissibility grounds could be considered “social grounds” that the drafters of the 1954 Convention did not envision being included under Article 31.490 b. Article 31(3) Under the IRPR, a foreign national subject to a removal order may be granted time to leave the country voluntarily.491 This, in theory, provides the person with time to seek legal admission to another country. However, when a de jure stateless person is issued a removal order and requested to leave Canada voluntarily, they will likely be unable to leave because they do not possess a legal status in any other country. Without the ability to leave, there is a real possibility that a stateless person will remain in legal limbo indefinitely.492 The Minister may still attempt to enforce the removal order of a stateless person when there is no possibility for them to leave Canada.493 This can occur because Canada simply treats stateless persons like any other foreign national in the absence of a formal statelessness determination procedure. The IRPR provides that in cases where the Minister enforces removal, a foreign national is to be removed to the following possible countries: • The country from which they came to Canada; • The country in which they last permanently resided before coming to Canada; • A country of which they are a national or citizen; or • The country of their birth.494 IRPA, ibid., at ss. 34-41. See also, Citizenship and Immigration Canada, ENF 1 Inadmissibility (4 September 2013), available at: http://www.cic.gc.ca/english/resources/manuals/enf/enf01-eng.pdf [ENF 1 Manual]; Citizenship and Immigration Canada, ENF 3 Admissibility, Hearings and Detention Review Proceedings (29 April 2015), available at: http://tinyurl.com/pxkzc2h. [ENF 3 Manual]; ENF 10 Removals, supra note 449. 488 See IRPR, supra note 21 at s. 228; and ENF 3 Manual, ibid., at 8. 489 See IRPR, ibid., at s. 228-229. 490 IRPA, supra note 20 at ss. 38-42. 491 IRPR, supra note 21 at s. 240. 492 Statelessness in the Canadian Context, supra note 4 at 54-57. Andrew Brouwer discusses the issues of stateless persons subject to a removal order at length, some of which is summarized again in this report. 493 IRPR, supra note 21 at s. 239. 494 Ibid., at s. 241. 487 101 101

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