As lawyers in Quebec especially, we are particularly concerned with Bill C-12, because many foreign nationals in Quebec come from moratorium countries. Moratorium countries were mentioned last week, I think. Essentially, these are countries that Canada will not remove people to, in general, because the overall security situation is so bad. Examples of countries under a moratorium right now include Haiti, the Democratic Republic of Congo, Venezuela, Mali, Yemen and Ukraine, among others.
If someone from one of these countries falls into the two categories mentioned in Bill C-12 that I've already discussed, their only option to seek protection is the PRRA, the pre-removal risk assessment. However, a pre-removal risk assessment can only be offered when a removal is scheduled. If they come from a country where they can't be removed to, they end up in this legal limbo where they can't make an asylum claim and they can't ask for a PRRA. They're just kind of stuck in Canada in between. As lawyers working in a province that is home to many people from especially Haiti and the Democratic Republic of Congo, we find the possibility of so many people falling into this situation to be very problematic.
AQAADI strongly suggests that Bill C-12 not be passed unless the proposed amendments to paragraph 101(1)(b) of the Immigration and Refugee Protection Act be removed, as they risk compromising the efficacy of our refugee system. At the very least, there should be exceptions in the law for specific situations, such as for cases of domestic violence, unaccompanied minors, LGBTQ+ claims and people who come from countries where the situation has changed significantly since they arrived.