CITIZENSHIP AND IMMIGRATION
Immigration Practice
Appeal from Federal Court’s dismissal (2004 FC 1641) of application for judicial review of second Refugee Protection Division’s (RPDs) denial of refugee status—Issue estoppel, res judicata reviewed—Certified question as to whether reviewable error in RPD’s failure to expressly address factors submitted by parties when exercising discretion to apply issue estoppel not arising on facts—RPD’s decision grounded in facts occurring after decision rendered by Convention Refugee Determination Division on first claim—Appeal dismissed.
Erdos v. Canada (Minister of Citizenship and Immigration) (A‑16‑05, 2005 FCA 419, Pelletier J.A., judgment dated 9/12/05, 12 pp.)
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