As was explained previously, there are other kinds of decisions comparable to this decision; in other words, a grant of citizenship where the minister or the minister's delegate is making the decision.
The way the present Citizenship Act is structured--and we have to remember the act has been in place fundamentally since 1977--the review mechanism that exists for that kind of decision is judicial review without the requirement for leave. This is a review where the Federal Court is looking at the case where it's been appealed, or where a review has been asked for by the client, and determining if the decision made by the citizenship officer was reasonable. If the Federal Court judge feels the decision was not reasonable, it will be sent back for readjudication by a new citizenship officer.
The kind of appeal the Canadian Bar Association has been suggesting, either to the Immigration Appeal Division of the IRB or to the Federal Court, is something that does not currently exist in the Citizenship Act. The concern is, by creating a distinction between that group of adopted children and not giving other individuals the same kind of appeal, you're again creating a distinction between one group in the context of citizenship and another group.
On the last point on the IAD, the IRB, the Immigration and Refugee Board, has no jurisdiction in citizenship. Their mandate flows from IRPA, the Immigration and Refugee Protection Act, and there is no mechanism in the Citizenship Act for them to have jurisdiction, so there is no precedent for the IRB to pick up citizenship applications.
Finally, I think it's also important to highlight that it will be up to the parent to choose which approach they want to take. Do they want to take the IRPA process with certain extra costs to that, in other words, processing costs, but also with the benefit of the IRB or the IAD appeal, or do they want to have access via the Citizenship Act? The individual, the parent for minor children, will have that choice--of picking either the IRPA process or the citizenship process.