In Tan v. Canada (Citizenship and Immigration) (Fed CA, 2026) the Federal Court of Appeal dismissed an appeal, this brought against a JR dismissal determining whether: "section 10 of the Citizenship Act, by which citizenship that was obtained by “false representation or fraud or by knowingly concealing material circumstances” may be revoked, violate paragraph 2(e) of the Canadian Bill of Rights".
Here the court considers the 'security of the person' element of Charter s.7:
[119] The right to security of the person under section 7 protects against physical punishment and the threat thereof, imprisonment and detention, and serious and profound psychological distress, a requirement far beyond the normal stress and anxiety that may arise because of state action: Canadian Council for Refugees at para. 90; New Brunswick (Minister of Health and Community Services) v. G.(J.), 1999 CanLII 653 (SCC), [1999] 3 SCR 46 at para. 60.
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