Actually, the State Immunity Act already has an exception for criminal cases, and there are provisions in the Criminal Code that implement the torture convention. As Jayne mentioned in her opening statement, they're not used at the moment because, I understand, the RCMP office that is in charge of investigating those crimes doesn't have much of a budget. But in theory, crimes committed abroad, especially crimes against humanity, can be prosecuted in Canada, including public officials, and their immunity has been removed through the State Immunity Act. So whatever we're saying here today is about civil cases. It's translating that immunity we've removed in criminal cases to civil cases so that you can also have compensation for the victims themselves.
We have here the common law system, where in criminal cases the crown prosecutes the criminals. In the continental legal system, private parties can join the prosecution and claim civil damages. That's what they call the partie civile in France. So it is possible in those European countries for a victim of torture to actually join the prosecution and ask for compensation against foreign officials, whereas, here, in Britain, and in common law countries we don't have that possibility. The only way to do this is to remove the immunity that's actually built into the State Immunity Act, especially for gross violations of international law.