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2019 RLLR 204

Citation: 2019 RLLR 204
Tribunal: Refugee Protection Division
Date of Decision: April 11, 2019
Panel: Miryam Molgat
Counsel for the Claimant(s): Larry W Smeets
Country: Egypt
RPD Number: VB8-02869
Associated RPD Number(s): VB8-02882, VB8-02883
ATIP Number: A-2020-00518
ATIP Pages: 002857-002873

REASONS FOR DECISION

[1]       XXXX XXXX XXXX XXXX XXXX (the “claimant” aka “the principal claimant” aka “the mother”), XXXX XXXX XXXX XXXX XXXX (“the associated claimant” aka ” the son” aka “the male claimant”), and XXXX XXXX XXXX XXXX XXXX (“the associated claimant” aka “the daughter”) claim to be citizens of Egypt and are claiming refugee protection pursuant to sections 96 and 97(1) of the Immigration and Refugee Protection Act (IRPA).1

DETERMINATION

[2]       The panel finds that the principal claimant and the male claimant are not Convention refugees as they do not have a well-founded fear of persecution on a Convention ground in Egypt. The panel also finds that the principal claimant and the male claimant are not persons in need of protection pursuant to section 97(1) of the IRPA.

[3]       The panel finds that the daughter is a Convention refugee as she does have a well-founded fear of persecution on a Convention ground in Egypt. Its reasons are as follows:

ALLEGATIONS

[4]       The claimants’ complete allegations are set out in the Basis of Claim Form (BOC)2 and need not be repeated here in detail.

[5]       To summarize briefly, the principal claimant is a woman born in XXXX. She is a long- time resident of Saudi Arabia. She came to Canada with her two minor children. She came because she feared female genital mutilation and/or forced marriage being imposed on her minor daughter, the associated claimant. She feared this might happen at the hands of her in-laws, who she describes as a very conservative, powerful and influential family in Egypt. She describes her mother in law and her four children as fanatic Sunni Muslims. The in-laws, upon learning that the daughter had reached puberty, demanded that she undergo Female genital mutilations (FGM) so that she could marry after the procedure. The principal claimant underwent FGM as a child. The claimant also fears that her minor children might be abducted as there is a problem in Egypt with human organs sold on the black market.

[6]       In Egypt, the principal claimant still has her mother, and three brothers and a sister, all residing in Cairo.

[7]       The claimants also allege fear of risk to their lives, risk of torture or risk of cruel and unusual treatment or punishment at the hands of the same agent of harm.

[8]       The claimants allege that neither state protection nor safe and reasonable internal flight alternatives are available in their country of nationality.

Chairperson’s Guidelines

[9]       In coming to this determination, the panel has considered the Chairperson’s Guidelines on Women Refugee Claimants Fearing Gender-Related Persecution3 and in particular, Part D, which addresses special problems faced by women in demonstrating that their claims are trustworthy and credible at determination hearings. Sorne of the factors noted include cross­ cultural misunderstandings and violence-related trauma. The panel has considered these guidelines while assessing questions regarding subjective fear in the claim of the female claimants. Reasons for drawing on these guidelines include objective country conditions evidence and how they relate to the claimant herself at the time of the hearing. The panel has also considered Guideline 3: Child Refugee Claimants: Procedural and Evidentiary Issues4 in coming to a decision in the claims of the minors.

ANALYSIS

[10]     The main issues are credibility and subjective fear and Internal Flight Alternative (IFA).

DESIGNATED REPRESENTATIVE

[11]     The principal claimant was appointed as Designated Representative for the two associated claimants, who are both minors.

Identity

[12]     The claimants’ identities and citizenship have been established by the testimony and supporting documentation filed and entered in these proceedings. The passports are on file,5 along with other documents.

Nexus

[13]     For the claimants to be Convention refugees, the fear of persecution must be “by reason of’ one of the five grounds enumerated in the Convention refugee definition. In other words they must have a well- founded fear of persecution for reasons of race, religion, nationality, membership in a particular social group or political opinion.

[14]     The panel finds that the harm feared by the daughter is by reason of membership in particular social group as females fearing female genital mutilation and/or forced marriage. For the mother, the nexus is membership in a particular social group as a female seeking to prevent FGM and/or forced marriage of her minor daughter. The panel finds that the harm feared by the son is also by reason of one of the five grounds enumerated in the Convention refugee definition, namely membership in a particular social group, in this case, family member of his mother and sister, whose nexus is gender-based.

Credibility

[15]     When credibility is assessed there are two principles that are followed. Firstly, when a claimant swears to the truthfulness of certain facts there is a presumption that what he is saying is true unless there is reason to doubt it.6 Secondly, when assessing credibility the panel is entitled to rely on rationality and common sense.7 The determination as to whether a claimant’s evidence is credible is made on a balance of probabilities.

[16]     The panel accepts that the principal claimant has undergone FGM and that she is opposed to her minor daughter being submitted to it. The panel accepts that the claimants are unable to return to Saudi Arabia to live and work. This matters as it means that their claims must be assessed in the context of Egypt only. The evidence on the possibility of return to Saudi Arabia was inconsistent as the husband, in his testimony, said the principal claimant’s work position has been “saudified”. This is not what the principal claimant said, as she testified that her husband’s position had been “saudified” and that, as a result, her own status in Saudi Arabia was in peril. Either way, the panel accepts that the claimants cannot return to Saudi Arabia to live and work.

[17]     The principal claimant’s evidence on the year of the fateful trip to Egypt and resulting kidnapping in Cairo was inconsistent. She orally confirmed her oral testimony that the year of the trip was 2017. When it was put to her that her BOC says it was in 2016, her explanation was that she had noticed it when completing the BOC and had told the BOC interpreter to correct it. When asked why, then, she affirmed a non-corrected BOC of which she said she knew the contents, the claimant said that it was because the BOC interpreter told her he had corrected the error. The claimant also suggested that the panel ask the BOC interpreter about the matter. It is the claimant’s responsibility to establish the elements of her claim, not the panel’s. The claimant offered to get proof from the BOC interpreter that he had made this mistake, but she failed to do so. This is in spite of the resumption in the hearing being set after this initial testimony was taken. The panel draws a negative inference, finding that this is a material inconsistency which is not reasonably explained. This matters as the claimant repeatedly stated that the problems with her in-laws began around the end of 2016 or early 2017, when her daughter had her first menstrual period. The panel draws a negative inference and finds she would have gotten the year right if it had happened as alleged.

[18]     This inconsistency relating to the year of the trip to Egypt also matters as the claimant, when asked why, if she knew, as alleged, by the XXXX of 2017, that her in-laws intended to forcibly perform FGM on the daughter and marry her off, why she decided to go to Egypt a few months later with her daughter. The principal claimant’s explanation was that she needed to process the renewal of her work visa. She also said that her mother was ill and she needed to go see her. The panel finds this is insufficient explanation for a lack of subjective fear demonstrated by the claimant’s re-availment to Egypt, the daughter’s in the XXXX of 2017 and/or the XXXX following her first menstrual period. This is all the more damaging to the claims given that the claimant had a US visa issued in XXXX 2016 which she could have used to travel to the USA instead of going to Egypt in the summer.

[19]     The fact that the claimant did travel to the USA in XXXX 2016, on her US visa issued in XXXX 2016, is damaging to the claim as, if the panel accepts, for the sake of analysis, that the threat to perform FGM on the daughter was made in the XXXX of 2016, then it begs the question of why the claimant failed to make an asylum claim in the USA and why she returned to Saudi Arabia, to then travel later that summer, or the following summer, to Egypt. Either way, even if the panel were to accept that, in fact, the abduction of the daughter took place in XXXX 2016 and not 2017, the principal claimant’s behavior is problematic and raises significant credibility and subjective fear issues. The panel finds that the inconsistency in the timing of the abduction of the daughter, be it in 2016 or 2017, is problematic either way. That is the case because the claimant chose to return to Egypt with her daughter after learning of her in-laws’ intentions against her daughter. It is also because, if the claimant learned this in early 2016, it leaves the question of why she herself failed to make an asylum claim in the USA when there in XXXX 2016. As seen in these Reasons, the claimant’s explanation for this failure to claim in the USA was problematic. This is significant as the claimant alleges that her own life is at risk as a result of her in-laws’ intentions.

[20]     The panel finds that the claimant has not established that her in-laws have the ongoing motivation and capacity to harm her or her daughter or her son. The reason for this is that the claimants spent 4-5 days after threats uttered against them, after the principal claimant went to the police right after picking up her daughter from her sister in law XXXX home, where the daughter was being forcibly prepared for FGM. This gives the agents of persecution plenty of reason to want to harm or re-abduct the daughter, and to carry out their threats against the principal claimant. Instead, the in-laws did not harm the claimants, who remained in the claimants’ family home for four to five days. The principal claimant confirmed that the in-laws knew where she was at his time. During that time, there was no physical interference, no reported physical contact at all, and the claimants were able to leave Egypt for Saudi Arabia in a normal fashion without their exit or freedom of movement being otherwise impeded. In addition, the principal claimant was able to go about dealing with the paperwork required to renew her work permit in Saudi Arabia without being impeded. Presumably, that required her physical presence. The panel finds that, if the agents of persecution were intent on harming the claimants, they would have done so. That is because they knew their location during these four to five days. The claimant alleges that, during those four or five days, her in-laws went to her family home, saying to her: “who do you think you are?” They also allegedly threatened her by saying that they can reach her at any point in any way. The panel finds that this was an empty threat, which the in-laws did not act on in spite of the opportunity to do so. The panel accepts that the in-laws harbor ill will towards the claimant, but the panel finds that does not mean that they will act on it. This is all the more so given that the claimant had gotten her way, by securing her daughter, taking her away from her aunt Iman’s home, and committing the affront of reporting the matter to the police. Surely this would warrant more than empty threats from someone intent on carrying out the threat and/or imposing FGM on the daughter and/or killing the principal claimant for her opposition to such things being perpetrated on her daughter.

[21]     The panel finds that the claimant has not established that her in-laws have the power or influence which she attributes to them. She testified that she knows they have influence because they do not let her out of her sight. She also testified that, according to tradition, they have all the habits and influence. This is insufficient credible and trustworthy evidence. It is too vague, and insufficiently grounded in any kind of specific, clear evidence of power or influence which is separate from the claimant’s belief t in its existence. This weakness of the claimant’s evidence exists in spite of repeated questions by the panel bearing on the power and reach and influence of the in-laws. The panel further notes that neither the claimant’s sister nor her husband, in their letters of support in exhibit 4, mention any of this when referring to the in-laws. The sister says that the claimants were chased everywhere by the in-laws. The panel does not take this as evidence of the in-law’s influence or presence throughout Egypt. The claimant alleged that, during the trip to Egypt when her daughter was abducted, she went to XXXX XXXX XXXX, where her in-laws targeted her by telephone. She also alleged that she then went to Cairo, where she was targeted. This, in fact, raises yet more credibility questions regarding why she later went to Cairo, where she knew her in-laws reside. The husband’s relatives appear to have lost interest and have retreated into excommunicating those family members whose behavior or values they reject, such as the husband’s. The panel notes that, in spite of the husband’s family alleged influence, there is insufficient credible and trustworthy evidence that they have threatened him since breaking off contact with him. This is yet another indication, in the panel’s mind, that his family do not have the motivation and/or capacity to pursue the claimants, given that this ex­ communication directly relates to the claimants.

[22]     The panel finds that the claimant has not established that her in-laws or their clan are present throughout Egypt and/or in XXXX XXXX XXXX. When asked, she said they are present in Assouan, Cairo and perhaps, the Sinai. The panel notes that this is unclear evidence pertaining to the Sinai. The panel finds that the claimant has not established on a balance of probabilities that her in-laws are anywhere except Assouan and Cairo. This matters to the question of the geographical reach of the in-laws, which in turn relates to the question of IFA in XXXX XXXX XXXX. It also matters as it relates to the influence of the in-laws. The claimant has not established that the in-laws have influence outside of Cairo and Assouan.

[23]     The claimant failed to establish with sufficient credible and trustworthy evidence that her in-laws have the power and influence in Egyptian society that she alleges. When asked, her answers were vague and circular. The husband’s testimony that his family are a well-established and well-connected, wealthy family with influence is insufficient. That is because, though asked more than once, he failed to provide any specific indication of his family’s influence. This credibility finding matters as it relates to a lack of sufficient evidence which is material to the question of IFA.

[24]     The claimant referred to the registry where she would have to register if she moved to the proposed IFA. The panel accepts the existence of this registry, but does not see how it matters given that the claimant has not established that the agents of harm have the motivation and capacity to seek and/or obtain her personal information through the registry.

[25]     Counsel in his questions tried to establish that the possibility of the husband having ongoing communication with the claimants were in the proposed IFA would pose a risk of serious possibility of persecution to the claimants in the IFA. This, in counsel’s view, would be as a result of his own past wavering position on the question of FGM as it applies to his daughter. Counsel also tried to make the case that the future would yield foreseeable pressure on the husband from the in-laws, implying that the husband would waiver and that this would result in a serious possibility of persecution for the claimants. The panel finds that the counsel has not made out his case in either of these assertions. That is because his views are not supported by sufficient credible and trustworthy evidence. When one looks at what the claimant knows and has experienced, her evidence is different and does not support counsel’s point. That is because the claimant clearly stated more than once in testimony that her husband now shares her position regarding FGM as it applies to the daughter. The claimant clearly stated that there is no flexibility in regard to FGM and the daughter, i.e. that it cannot happen. The claimant said this in the context not of her own personal will, but rather in the context of the couple she forms with her husband. What counsel is suggesting amounts to speculation and, as such, does not merit much weight.

INTERNAL FLIGHT ALTERNATIVE (IFA)

[26]     The following possible IFA was put to the claimant: XXXX XXXX XXXX.

First prong: no serious possibility of persecution or no personalised risk under subsection 97(1).

[27]     The panel finds that the proposed IFA, on a balance of probabilities, does not pose a serious possibility of persecution in the IFA as defined in section 96 of IRPA and/or a risk to life or risk of cruel and unusual treatment or punishment or a danger of torture in the IFA – as per subsection 97(1) of IRPA for the claimants. The persecution and/or risk to life envisaged in this section relates to the threats of FGM and/or early or forced marriage on the daughter. This analysis is done on a balance of probabilities. Once the IFA has been identified, the onus of proof that the IFA is not viable is on the claimants. As seen in the above credibility analysis, the claimants have not established that the agents of persecution have the motivation or capacity to track them in the proposed IFA. The agents of persecution had the opportunity to persecute the claimants in Cairo and did not do so. This was in spite of their continued contact at the time with the claimants. In addition, the husband is now a staunch ally of the claimants in regards to their fear of persecution. The claimant described her husband in these terms and he testified accordingly providing evidence which supported the principal claimant’s testimony in this regard. Furthermore, the husband’s relationship with his own family of origin has evolved as they have excommunicated him as a result of his staunch support of the principal claimant against his own family’s wishes. For these reasons, it is not credible that the in-laws would locate the claimants in XXXX XXXX XXXX as there is insufficient credible and trustworthy evidence that they would seek to do so or know how to do so.

[28]     The principal claimant alleges that, as someone who would oppose any FGM or forcible marriage on her daughter, she herself would be face a serious possibility of persecution. As for the forward-looking risk of FGM for the daughter in the IFA, the country conditions documents speak to a diminishing risk and rate of FGM for her generation.8 Furthermore, there is insufficient credible evidence that anyone other than her father’s family would seek to impose it on the daughter. As that allegation is resolved by an IFA, the principal claimant’s claim on this ground fails. The same can be said for the risk of forced marriage being imposed on the daughter. There is insufficient credible and trustworthy evidence that the possibility of persecution comes from anyone other than her father’s family. As is the case for FGM, that possibility is undermined by the panel’s finding of an IFA, and its earlier finding of lack of motivation and capacity of the in-laws to locate and harm the claimants in the IFA. In either case, be it FGM or forced marriage, the daughter is shielded in effect from societal risk by her parents’ staunch resolve to prevent that from happening to her. There is insufficient credible and trustworthy evidence that there is a serious possibility of persecution for the principal claimant in the IFA. This also impacts any related possibility of persecution for the son based on his membership in the family.

Second prong: IFA is objectively reasonable, in all the circumstances:

[29]     Having considered the conditions in geographic area and all the circumstances of this case, including those particular to the claimants, the panel finds that it is objectively reasonable for the claimants to seek refuge in the proposed IFA for the following reason. Once the IFA has been identified, it is up to the claimants to establish that it is not a viable solution. The claimants have failed to establish that the proposed IFA is not objectively reasonable, in all the circumstances.

RESIDUAL CLAIMS OF THE PRINCIPAL CLAIMANT AND SON

[30]     Although significant and repeated discrimination may amount to persecution, whether or not it rises to the level of persecution depends on the particular circumstances of the case. Persecution is defined as the systematic or sustained or repeated violations of one’s fundamental human rights. When considering whether the principal claimant faces cumulative discrimination amounting to persecution resulting from sexual harassment of women in Egypt, the panel finds that the claimant had an insufficient explanation for why she took the repeated prolonged trips to Egypt if the sexual harassment was problematic for her. This is important as each time she returned to Egypt, she was essentially exposing herself to a risk which she has not alleged as existing in Saudi Arabia, her country of residence at the time. The panel notes that the claimant said she would go to Egypt to visit her family and to renew her Saudi work permit. The trip the claimant took to XXXX XXXX XXXX appears to serve neither of those goals, thus undermining the reasoning that the only reason for her return to Egypt was to see family and renew her work visa. The claimant has also failed to establish why renewing her work permit and seeing her family necessitated lengthy such frequent trips to Egypt. Her passports bear stamps that document trips to Egypt occurring more than once a year on average.9 Given the weak evidence from her in regards to sexual harassment in Egypt, this is inconsistent with a finding that she chose out of necessity to put up with the sexual harassment each time she returned to Egypt.

[31]     The panel also notes that the claimant failed to reasonably explain why she failed to claim asylum when in the US prior to the trip to Egypt when her daughter was abducted. Absent further credible and trustworthy evidence, the claimant’s explanation of anti-Muslim sentiment in the US as a result of the voting in of Mr. Trump as US president cannot stand as a reasonable explanation for her failure to seek asylum in the US at this time on the grounds of sexual harassment in Egypt. That is because, at that time, the US presidential elections had not been held and Mr. Trump was not the anticipated candidate and/or winner of it. The claimant’s lack of subjective fear of the sexual harassment she faced in Egypt also came out of her failure to follow counsel’s lead when questioned on her statement that she had to stay home 24/7 as a result of sexual harassment. Her testimony that she thought of making an asylum claim in the US based on her female gender is undermined by her explanation that the problems did not start until 2017, before which her daughter had not yet reached puberty. Her evidence, when seen as a whole, is insufficient to sustain a positive determination based on a risk of sexual harassment as it applies to her.

[32]     The panel accepts that, as a general rule, women suffer discrimination or harassment in Egypt. In some cases this discrimination or harassment can amount to persecution. The documentary evidence lists the following factors among women: education, wealth, age, marital status, rural versus urban residence, and the specific geographic area of Egypt where the person resides. These factors are described as impacting, among other things: early or forced marriage, exposure to FGM and pro-FGM attitudes, access to education, age at first birth, whether it is a home birth, and access to employment.10 There is also information that the “relative level of participation of women in household decision-making is positively correlated to their age and level of education and wealth”.11 The panel finds that this objective evidence supports a finding that not all women in Egypt face discrimination amounting to persecution, as not all women are equally affected. That is in spite of widespread sexual harassment in the country.

[33]     It was up to the claimant to establish that the sexual harassment and/or other discrimination she faces as a woman in Egypt, when seen cumulatively, rises to the level of persecution in her particular case. She failed to do so. This failure on the part of the claimant is all the more significant given that, as she had lost her long-time status in Saudi Arabia, she was well aware that she faced returning to reside and work in Egypt. This failure on the part of the claimant to establish a case is also all the more significant given that, during the many years she spent residing in Saudi Arabia, she returned regularly to Egypt where she visited family. Her contacts with her family and, presumably, others in Egypt, during these trips, would have given her information and knowledge on the question of sexual harassment and/or discrimination against women beyond her own experiences during those numerous trips. The claimant’s testimony that, as a woman, she had to stay indoors in Egypt “24/7” is insufficient given her insufficient explanations for her lack of subjective fear in the face of this and the previously mentioned credibility issues arising out of her evidence in regard to this aspect of her claim. She failed to establish how the social context of Egypt vis a vis women impaired or nullified her enjoyment of her fundamental human rights, or how the institutionalized attitudes that discriminate against women would impact her in such a way that it would amount to persecution. It is worth noting in this regard that she was able, without male support, to turn to the police in Egypt. She also managed to change her husband’s position regarding his own family and the physical integrity of their daughter. These are positive indicators of the claimant’s ability to function as a woman in Egyptian society, even when going against the tide. The panel finds the claimant, as a female, faces discrimination and not persecution in Egypt.

RESIDUAL CLAIM OF DAUGHTER

[34]     The panel finds that the evidence pertaining to the daughter on the possibility of sexual harassment and/or discrimination amounting to persecution in Egypt is quite different from her mother’s. The daughter did not testify. As a result, there are no credibility problems stemming from her testimony. As she is a minor, there is no requirement for her to demonstrate subjective fear. The weakness of the advocacy of her claim by her Designated Representative should not count against her. The life choices of the mother in regard to her own allegations of sexual harassment amounting to persecution should not count against her daughter. The panel has considered that, as a minor, the proper approach is to assess her evidence from a child-centered perspective. The panel is mindful that what does not amount to persecution for an adult may well constitute persecution for a minor. The panel appreciates that “children have distinct rights, are in need of special protection, and can be persecuted in ways that would not amount to persecution of an adult”. “Physical violence and the sexual harassment of women remains widespread in Egypt, despite harassment being made a criminal offence in June 2014.”12 The daughter is XXXX years old. She is young enough for a return to Egypt to impact on her development. When one looks at the objective basis for the daughter’s residual claim of discrimination amounting to persecution resulting from cumulative sexual harassment of females in Egypt, the panel finds that her case is made out. The objective country conditions evidence describe wide-ranging, country-wide sexual harassment of women.13 “Sexual harassment and violence in public places is an ongoing problem for women in Egypt”.14 As a XXXX-year old female having reached puberty, the daughter would be impacted by this state of affairs. Given her young age, it is reasonable to conclude that, in her case, it would reach the threshold of persecution. In the specific case of the daughter when faced with this, there is no state protection as “[t]here do not appear to be any mechanisms in place to ensure implementation of the legal framework relevant to sexual harassment”.15 There is no available IFA. The daughter therefore faces a serious possibility of persecution throughout Egypt.

[35]     Turning to the son, his claim has not been established and fails for this reason. The residual claim of risk of organ harvesting to children is not covered by s. 96 or s. 97 of IRPA. It is an opportunistic crime, which exists as a generalized risk for large segments of the Egyptian population. There is insufficient credible and trustworthy evidence that the risk of this happening to the son is higher or different than for large segments of the population, or that it is a risk to children because they are children.

CONCLUSION

[36]     Having considered all of the evidence, the panel determines that there is not a serious possibility that the principal claimant or her son would be persecuted in their country of nationality for any of the five grounds enumerated in the Refugee Convention. The panel also finds that the claimants are not persons in need of protection pursuant to section 97(1) of the IRPA.

[37]     The principal claimant and her son have an IFA.

[38]     The panel concludes that the principal claimant and her son are not Convention refugees or persons in need of protection and the panel therefore rejects their claims.

[39]     Having considered all of the evidence, the panel determines that there is a serious possibility that the daughter would be persecuted in her country of nationality for one of the five grounds enumerated in the Refugee Convention. She does not have an IFA. The panel concludes that the daughter is a Convention refugee. The panel accepts her claim.

(signed)           MIRYAM MOLGAT

April 11, 2019

1 Immigration and Refugee Protection Act, S.C. 2001, c. 27.

2 Exhibit 2.

3 Immigration and Refugee Board of Canada (IRB) Chairperson’s Guideline 4: Women Refugee Claimants Fearing Gender-Related Persecution, November 1996.

4 Guideline 3: Child Refugee Claimants: Procedural and Evidentiary Issues: Guidelines issued by the Chairperson pursuant to Section 65(3) of the Immigration Act, September 30, 1996.

5 Exhibit 1.

6 Maldonado v. Canada (Minister of Employment and Immigration). [1980] 2 F.C. 302, 31 N.R. 34 (C.A.).

7 Shahamati, Hasan v. Minister of Employment and Immigration (F.C.A., no. A-388-92), Pratte, Hugessen, McDonald, March 24, 1994.

8 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.7: Country Profile: FGM in Egypt. 28 Too Many. April 2017. Note: Subsequent to the hearing, the National Documentation Package on Egypt was updated March 29, 2019. It contains no material differences with the version in use at the time of the hearing.

9 Exhibit 4, pages 1-56.

10 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.7: Country Profile: FGM in Egypt. 28 Too Many. April 2017.

11 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.7: Country Profile: FGM in Egypt. 28 Too Many. April 2017.

12 Kim v Canada (Minister of Citizenship and Immigration), 2010 FC 149, [2011] 2 FCR 448.

13 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.7: Country Profile: FGM in Egypt. 28

Too Many. April 2017. Also see Sections 2 and 5 of NDP, Egypt, 29 March 2019.

14 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.7: Country Profile: FGM in Egypt. 28 Too Many. April 2017.

15 Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.2: Egypt. Social Institutions and Gender Index 2014. Organisation for Economic Co-operation and Development.

Exhibit 3, National Documentation Package, Egypt, 29 March 2019, tab 5.1: Treatment of women who do not conform to Muslim practices and traditions, including wearing a veil (head covering), in rural and urban areas; state protection available to victims of mistreatment (June 2013-November 2014). Immigration and Refugee Board of Canada. 26 November 2014. EGY105005.E.