Based on the current regulatory framework, I do not believe that a consultant has the core competencies to represent any individual before any tribunal of the Immigration and Refugee Board of Canada. I do not believe they should be doing detention reviews at the immigration division, or determinations that someone is a member of a terrorist organization at the immigration division. I don't believe they should be representing refugee claimants at the refugee protection division.
I don't believe they should be doing appellate-level written advocacy at the refugee appeal division, and I don't believe they should be appearing before the immigration appeal division. That is a court of competent jurisdiction, and it is very much if not identical to a court.