In 2013, the Supreme Court of Canada in Ezokola v. Canada (Citizenship and Immigration) created a new test for determining complicity in Article 1F(a) exclusion cases. Article 1F(a) of the 1951 Refugee Convention provides that: The provisions of this Convention shall not apply to any person with respect to whom there  are serious reasons for considering that: (a)  He has committed a crime against peace, a war crime, or a crime against humanity, as defined in the international instruments drawn up to make provision in respect of such crimes; The issue that Ezokola addressed […]

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