with a Minister’s delegate, there is a concern that the procedural requirements of Article 31(2) may not be satisfied. Finally, the risk of stateless persons being detained indefinitely and removed to countries where they do not have a legal status or right to entry illustrates a lack of consideration for stateless person’s circumstances. a. Canada’s International Human Rights Obligations In order to fill some of the gaps between Canada’s legal framework and the 1954 Convention, Canada is reminded of its international human rights obligations under Article 13(1) of the ICCPR, which states: An alien lawfully in the territory of a State Party to the present Covenant may be expelled therefrom only in pursuance of a decision reached in accordance with law and shall, except where compelling reasons of national security otherwise require, be allowed to submit the reasons against his expulsion and to have his case reviewed by, and be represented for the purpose before, the competent authority or a person or persons especially designated by the competent authority.502 Furthermore, as explained in the Handbook on Protection of Stateless Persons, there is risk of stateless persons being subject to arbitrary and indefinite detention due to the nature of statelessness and lack of consideration of their circumstances. Indefinite and arbitrary detention is contrary to Canada’s international human rights obligations under Article 9(1) of the ICCPR: 112. …Statelessness, by its very nature, severely restricts access to basic identity and travel documents that nationals normally possess. Moreover, stateless persons are often without a legal residence in any country. Thus, being undocumented or lacking the necessary immigration permits cannot be used as a general justification for detention of such persons. Article 9 of the International Covenant on Civil and Political Rights (“ICCPR”), guaranteeing the right to liberty and security of person, prohibits unlawful as well as arbitrary detention. For detention to be lawful, it must be regulated by domestic law, preferably with maximum limits set on such detention, and subject to periodic and judicial review. For detention not to be arbitrary, it must be necessary in each individual case, reasonable in all the circumstances, proportionate and non-discriminatory. Indefinite as well as mandatory forms of detention are arbitrary per se. 113. Detention is therefore a measure of last resort and can only be justified where other less invasive or coercive measures have been considered and found insufficient to safeguard the lawful governmental objective pursued by detention. Alternatives to detention – from reporting requirements or bail/bond systems to structured community supervision and/or case management programmes – are part of any assessment of the necessity and proportionality of detention. General principles relating to detention apply a fortiori to children who as a rule are not to be detained in any circumstances. […] 115. For stateless persons, the absence of status determination procedures to verify identity or nationality can lead to prolonged or indefinite detention. Statelessness determination procedures are 502 103 ICCPR, supra note 39 at Art. 13(1). 103