The Right of Citizens Abroad to Return During a Pandemic

Abstract

To prevent the spread of COVID-19 Canada has, like most other
states, temporarily limited access to its territory. It has, as requested
by international law, allowed the return of its own citizens. However,
in contrast to other countries, Canada has opted for a more restrictive
approach by requesting air carriers to deny boarding to any passengers abroad, citizen or not, with symptoms suggestive of COVID-19. In this article, we assess the legality of Canada’s approach regarding the return of citizens, both under international human rights law and Canadian constitutional law.

The full book is available at: https://ruor.uottawa.ca/handle/10393/40726

Full text

CHAPTER C-5
The Right of Citizens Abroad to Return
During a Pandemic*
Yves Le Bouthillier** and Delphine Nakache***
Abstract
To prevent the spread of COVID-19 Canada has, like most other
states, temporarily limited access to its territory. It has, as requested
by international law, allowed the return of its own citizens. However,
in contrast to other countries, Canada has opted for a more restrictive
approach by requesting air carriers to deny boarding to any passen-
gers abroad, citizen or not, with symptoms suggestive of COVID-19.
In this article, we assess the legality of Canada’s approach regarding
the return of citizens, both under international human rights law and
Canadian constitutional law.
Résumé
Le droit de retour des citoyens durant une pandémie
Pour empêcher la propagation de la COVID-19, le Canada, comme la
plupart des autres pays, a temporairement limité l’accès à son terri-
toire. Il a toutefois, comme le prescrit le droit international, autorisé
* The second part of this article draws on: Yves Le Bouthillier & Delphine Nakache,
“Is it Constitutional to Screen Canadians Trying to Board Flights Home?”, Policy
Options (7 April 2020), online: <policyoptions.irpp.org/magazines/april-2020/is-it-
constitutional-to-screen-canadians-trying-to-board-ights-home>.
** Full Professor, Faculty of Law, University of Oawa.
*** Associate Professor, Faculty of Law, University of Oawa.

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le retour de ses propres citoyens. Cependant, contrairement à d’autres
pays, le Canada a opté pour une approche plus restrictive en deman-
dant aux transporteurs aériens de refuser l’embarquement de tout
passager à l’étranger, citoyen canadien ou non, présentant des symp-
tômes apparentés à la COVID-19. Dans cet article, nous analysons la
légalité de l’approche du Canada concernant le retour de ses citoyens
au pays, tant au regard du droit international des droits de la per-
sonne qu’en vertu du droit constitutionnel canadien.
To prevent the spread of COVID-19, states around the world have
temporarily limited access to their territory. While some, such
as Morocco,1 decided to ban entry to everyone—including their own
citizens who are stranded abroad—most allowed their own citizens
to return, often through repatriation eorts. In doing so, these states
acted in a manner consistent with a citizen’s right in international
law to return to their country, as explained in the rst part of this
chapter. Once on national soil, citizens were assessed to determine if
they would need to self-isolate or be directed to a quarantine facility.
However, in contrast to other countries such as Australia and New
Zealand, Canada opted for control both on foreign soil and on arrival.
It requested that air carriers deny boarding to any passengers abroad,
citizen or not, with symptoms suggestive of COVID-19. In choosing
this more restrictive approach, Canada was an outlier. Whether this
approach was consistent with both Canada’s international obliga-
tions and the constitutionally protected right for citizens to return to
Canada is the focus of the second part of this chapter.
The “Right to Return” in International Law
In international law, “freedom of movement” is a generic term cover-
ing movements of individuals within a state as well as from one state
1. On March 13, 2020, Morocco suspended all international passenger ights to
and from its territory and announced its intention to not repatriate the esti-
mated 18,000 Moroccans stranded abroad. It commied, instead, to provid-
ing, through its consular ocers, basic assistance for accommodation, food,
and medicines. See Samir Bennis, “Morocco Should Move to Repatriate
Moroccans Stranded Overseas”, Morocco World News (19 April 2020), online:
<www.moroccoworldnews.com/2020/04/300036/morocco-should-move-
to-repatriate-moroccans-stranded-overseas>.

301
The Right of Citizens Abroad to Return During a Pandemic
to another. While the former embraces the right of persons to move
freely and to choose a place of residence within the territory of a state
(the internal aspect of freedom of movement), the laer covers the
right to leave any country (including one’s own), either temporarily or
permanently, and to enter or return to one’s own country (the external
aspect of freedom of movement). The rights to leave and return are
closely connected “in that the existence of one allows for the eec-
tive exercise of the other,”2 but they respond to dierent needs.3 The
person leaving a country may be doing so out of a desire to travel,
emigrate, or seek refuge; whereas the person seeking to return to
their country is usually motivated by a desire to return “home,” to the
“place where he or she belongs, to his or her roots.”4
The right to enter or return to one’s own country is embodied
in numerous international and regional human rights instruments,
including Article 12(4) of the International Covenant on Civil and
Political Rights (ICCPR) (“no one shall be arbitrarily deprived of the
right to enter his own country”).5 With the exception of Article 12(4)
of the ICCPR, all other instruments envisage no particular restriction
to its application. Moreover, while Article 12(3) of the ICCPR contem-
plates permissible limitations to a citizen’s right to move or leave their
state (when such limitations are “necessary to protect national secu-
rity, public order, public health or morals or the rights and freedoms
of others”), no such limitations apply to the right to return in Article
12(4). The only limitation to the right to return found in Article 12(4)
is in relation to the term “arbitrarily.” In 1999, the UN Human Rights
Commiee (UNHRC), a body of experts that monitors the implemen-
tation of the Covenant, interpreted this term very restrictively, stat-
ing “there are few, if any, circumstances in which deprivation of the
right to enter one’s own country could be reasonable.”6 Therefore, in
2. Sander Agterhuis, “The Right to Return and its Practical Application” (2005) 58:1
RHDI 165 at 168.
3. It is also worth highlighting that the “right to return” was originally considered
as a means for strengthening the “right to leave,” rather than as an independent
right in and of itself. See Report ofthe ThirdCommiee, UNGAOR, 3rd Sess, UN
Doc A/777 (1948).
4. Agterhuis, supra note 2 at 168.
5. For more on these instruments, see François Crépeau & Delphine Nakache, “The
Right to Leave and Return” in Rhona K M Smith & Christien van den Anker, eds,
EssentialsofHumanRights (London: Hodder Arnold, 2005), 222-24.
6. International Covenant on Civil and Political Rights, General Comment 27,
Freedomofmovement(Art12), UNHRCOR, 1999, 67th Sess, UN Doc CCPR/C/21/
Rev 1/Add 9 (1999), at para 19.

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international law, it appears that it would be only in exceptional cir-
cumstances, none of which have been identied by the commiee,
that the right to return could possibly be legally limited in ordinary
times.7
One legally possible justication for states to obstruct the exer-
cise of the right to return is through the derogation clause found at
Article 4(1) of the ICCPR. This article permits states parties to dero-
gate temporarily from some of their ICCPR obligations in times of
public emergency. It reads as follows:
In time of public emergency which threatens the life of the nation
and the existence of which is ocially proclaimed, the States Parties
to the present Covenant may take measures derogating from
their obligations under the present Covenant to the extent strictly
required by the exigencies of the situation, provided that such
measures are not inconsistent with their other obligations under
international law and do not involve discrimination solely on the
ground of race, colour, sex, language, religion or social origin.8
As Sarah Joseph notes, this provision is not a “blank cheque.”9
Derogations measures are only permied in extreme circumstances
and must be proportionate and consistent with other international
human rights obligations. Furthermore, there are rights (listed in
Article 4(2)) from which a state may never derogate.10 Finally, the state
7. The Travaux Préparatoires to the ICCPR reveal that the only limitation on this
right, expressed with the word “arbitrarily,” was intended to apply exclusively
to cases of lawful exile as punishment for a crime, whether accompanied by a
revocation of citizenship or not. However, in its concluding observations on
the Dominican Republic, the UNHRC stated in 1993 that “punishment by exile
is not compatible with the Covenant.” See Sara Joseph & Melissa Castan, The
InternationalCovenantonCivilandPoliticalRights, 3rd ed (Oxford: Oxford Univer-
sity Press, 2013). See also: Marc J Bossuyt, Guidetothe‘TravauxPréparatoires’ofthe
InternationalCovenantonCivilandPoliticalRights (Dordrecht: Martinus Nijho
Publishers, 1987), at 260-63; Manfred Nowak, UN Covenant on Civil and Political
Rights:CCPRCommentary (Kehl & Rhein, Germany: NP Engel, 1993) at 219.
8. International Covenant on Civil and Political Rights, GA Res 2200A (XXI), 21
UNGAOR, Supp No 16, UN Doc A/6316 (1966) at 52.
9. Sarah Joseph, “A Timeline of COVID 19 and Human Rights: Derogations in Time
of Public Emergency”, Grith News (5 May 2020), online: <news.grith.edu.
au/2020/05/05/a-timeline-of-covid-19-and-human-rights-derogations-in-time-of-
public-emergency>.
10. These are the right to life, the prohibition of torture and other cruel, inhuman,
or degrading treatment or punishment, the prohibition of slavery and servitude,

303
The Right of Citizens Abroad to Return During a Pandemic
has important procedural obligations with regard to derogations.
First, it must “ocially proclaim” the state of emergency (Article
4(1)), using its own domestic mechanisms for doing so. Second, it
must immediately notify the UN of any derogation (Article 4(3)).
Recently, the UNHRC and the UN Oce of the High
Commissioner for Human Rights claried the specic requirements
that states must meet when derogating from human rights with
respect to COVID-19.11 Recognizing that the pandemic may satisfy
the description of a “public emergency,” they highlighted that dero-
gation measures must be “strictly required by the exigencies of the
public health situation” and “limited…in respect of their duration,
geographical coverage and…scope.”12 As well, states’ derogation leg-
islation and measures must be the “least intrusive option among those
to achieve the stated public health goals” and provide “safeguards”
that guarantee the return to normal laws “as soon as the emergency
situation is over.”13 Finally, the UNHRC noted that a derogation is
not necessary when states parties “can aain their public health objec-
tives” by limiting a right “in conformity with the provisions for such
restrictions set out in the Covenant.”14 In other words, when limita-
tions on human rights are permissible, states should not resort to der-
ogation to protect their public health.
Limitations on international human rights are permissible in
“ordinary times,” provided they are proportionate measures pre-
scribed by law to protect public health and abide by the principles
of equality and non-discrimination. As noted earlier, however, these
limitations cannot justify a restriction to the right to return. The only
permissible limitation to the right to return for reasons of “public
health” is through the derogation clause, an “extraordinary mea-
sure” by which the right to return can be temporarily suspended or
restricted in response to a “full-edged national emergency—not a
the prohibition of imprisonment for inability to fulll a contractual obligation,
the prohibition against the retrospective operation of criminal laws, and the right
to recognition before the law.
11. Human Rights Commiee, Statement on Derogations from the Covenant in
ConnectionwiththeCOVID-19Pandemic, UNHRCOR, 2020, UN Doc CCPR/C/128/2
[UNHRCOR]; “Emergency Measures and COVID-19: Guidance” (2020), online
(pdf): UN Oce of the High Commissioner for Human Rights <www.ohchr.org/
Documents/Events/EmergencyMeasures_COVID19.pdf>.
12. UNHRCOR, ibid, at para 2(b).
13. UN Oce of the High Commissioner for Human Rights, supra note 11 at 2.
14. UNHRCOR, supra note 11, at para 2(c).

VULNERABLE
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mere public health emergency.”15 As of today, only a few states parties
to the ICCPR have complied with the strict procedural requirements
in relation to measures adopted to combat COVID 19.16 Therefore,
all other non-compliant states that have resorted to emergency mea-
sures—including Canada as discussed below—can be seen as hav-
ing already “derogated from their [procedural] obligations under the
ICCPR.”17 Beyond the fact that procedural requirements are not fol-
lowed, the above discussion reveals, more importantly, that it is not
legally possible under international law for states to obstruct the exer-
cise of citizens’ right to return unless it is truly justied in an emer-
gency situation.
Limits to the “Right to Return” in Canada During the COVID-19
pandemic
Starting in February 2020, Canada adopted a number of orders under
its Quarantine Act18 empowering its Chief Public Health Ocer to
compel any returning passenger to self-isolate at home or, for those
exhibiting signs of COVID-19, in a designated quarantine facility.19
On March 18, 2020, Canada took a more restrictive step, prohibiting,
through an interim order adopted under the Aeronautics Act,20 air
15. Adina Ponta, “Human Rights Law in the Time of the Coronavirus” (20 April 2020),
online: ASIL Insights <www.asil.org/insights/volume/24/issue/5/human-rights-
law-time-coronavirus>.
16. These states are Armenia, Chile, Colombia, Ecuador, El Salvador, Estonia, Georgia,
Guatemala, Kyrgyzstan, Latvia, Palestine, Peru, and Romania. See “OCHR &
Human Rights Commiee Address Derogations During Covid-19” (29 April
2020), online: International Justice Resource Center <ijrcenter.org/2020/04/29/ohchr-
human-rights-commiee-address-derogations-during-covid-19>.
17. Joseph, supra note 9.
18. Quarantine Act, SC 2005, c 20.
19. PC numbers 2020-0059 (3 February 2020); 2020-0070 (17 February 2020); 2020-
0071 (19 February 2020); 2020-0157 (18 March 2020); 2020-061 (20 March 2020);
2020-0162 (22 March 2020); 2020-0175 (24 March 2020); 2020-0184 (26 March
2020); 2020-0185 (26 March 2020); 2020-0260 (14 April 2020); 2020-0263 (20 April
2020). See Government of Canada, “Orders in Council Division” (30 April 2017),
online: Orders in Council online database <orders-in-council.canada.ca/results.php?
pageNum=4&lang=en>.
20. “Interim Order to Prevent Certain Persons from Boarding Flights to Canada
due to COVID-19” (18 March 2020), online: Transport Canada <www.tc.gc.ca/
eng/mediaroom/interim-order-prevent-certain-persons-boarding-ights-can-
ada-covid-19.html>. This order was updated a number of times after March 18.
The latest version is dated May 26, 2020. See “Interim Order to Prevent Certain
Persons from Boarding Flights to Canada due to COVID-19, No. 9”, online:

305
The Right of Citizens Abroad to Return During a Pandemic
carriers from allowing foreign nationals from boarding an aircraft
bound for Canada. Citizens and permanent residents were excluded
to entry. Exemptions were also provided for their immediate family
members and a number of other categories, including persons with
refugee status in Canada. On March 24, more stringent quarantine
measures were adopted. Persons who had no other options than
public transport (bus, train) to get to their residence to self-isolate
would be directed instead to quarantine facilities, as were those who
could not self-isolate without being in contact with vulnerable per-
sons (for instance, a returning passenger who shares a residence with
an elderly person) or without having access to basic necessities (such
as food).21
Canada’s rst series of measures were similar to those taken by
other states, such as Australia and New Zealand, whose immigration
regimes are often compared to Canada’s regime given that all three
are countries of immigration and have comparable legal traditions.
In Australia, borders were closed to international travellers on March
19, 2020, with the exception of citizens and permanent residents from
Australia as well members of their families. By reciprocal arrangement
with New Zealand, it also allowed for the entry of citizens from New
Zealand habitually residing in Australia. There were other exceptions
that could be considered by the Australian Border Force, for instance,
for compassionate reasons or for COVID-19-related medical services.22
All travellers arriving in Australia had to isolate for 14 days at a des-
ignated facility at their point of entry.23 The same day, New Zealand
adopted similar measures with slight dierences in terms of excep-
tions to the bar to entry.24 Since April 9, all returning passengers are
required to isolate for 14 days in managed facilities. Those identied
Transport Canada <www.tc.gc.ca/eng/mediaroom/interim-order-prevent-certain-
persons-boarding-ights-canada-covid-19-no-9.html>. See also: Aeronautics Act,
RSC, 1985, c A-2.
21. PC number 2020-0175 (24 March 2020). See Government of Canada, supra at
note 19.
22. “Coming to Australia | Covid-19 and the Border” (last visited 24 April 2020),
online: Australian Government DepartmentofHome Aairs <covid19.homeaairs.
gov.au/coming-australia>.
23. “COVID-19 Information” (last visited 12 May 2020), online: US Embassy &
Consulates in Australia <au.usembassy.gov/covid-19-information>.
24. “Border Closures and Exceptions” (last visited 13 May 2020), online: Immigration
New Zealand <www.immigration.govt.nz/about-us/covid-19/border-closures-and-
exceptions>.

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as being at high-risk of COVID-19 are placed in special quarantine
facilities.25 Many other countries did the same.
However, Canada went one step further. Starting on March 19,
2020, the government requested air carriers to prevent all travellers
abroad, including Canadian citizens, from boarding if they showed
symptoms suggestive of COVID-19.26 Air carriers had to conduct
health checks, relying on questions from a World Health Organization
(WHO) document that oers guidance for the management of ill trav-
ellers at points of entry.27 However, here, the government was requir-
ing air carriers to ask those questions before the plane departed from
a foreign country. This order was subsequently updated a number of
times. Later versions do not refer to the WHO document.28
Persons prohibited from boarding could not get on an aircraft
for at least 14 days unless they had a medical note certifying that their
symptoms were not related to COVID-19. Yet, the risk was real that 14
days later they could no longer leave a country either because there
were no longer ights available or because that country had closed its
borders.
Section 6(1) of the Canadian Charter of Rights and Freedoms29
provides that “[e]very citizen of Canada has the right to enter,
remain in, and leave Canada,” a right some citizens could no lon-
ger exercise since the government’s March 19, 2020, order to air car-
riers. The government could, however, justify this violation if, as
provided for in s 1 of the Charter, these limits can “be demonstrably
justied in a free and democratic society.” To do so, the government
has the burden to establish 1) that the measure is taken to address
a pressing and substantial objective; 2) that the measure is ratio-
nally connected to the objective; 3) that the measure impairs as lile
as possible the right in question; and 4) that the measure’s overall
25. Government of New Zealand, “COVID-19: Key Updates” (last visited 13 May
2020), online: Immigration New Zealand <www.immigration.govt.nz/about-us/
covid-19/coronavirus-update-inz-response>.
26. PC number 2020-0175 (24 March 2020). See Government of Canada, supra
note 19.
27. “Management of Ill Travellers at Points of Entry—International Airports,
Seaports and Ground Crossings—in the Context of COVID -19 Outbreak” (19
March 2020), online: World Health Organization <www.who.int/publications-
detail/management-of-ill-travellers-at-points-of-entry-international-airports-
seaports-and-ground-crossings-in-the-context-of-covid--19-outbreak>.
28. Government of Canada, supra, note 19.
29. Part I of the Constitution Act, 1982, being Schedule B to theCanadaAct1982 (UK),
1982, c 11.

307
The Right of Citizens Abroad to Return During a Pandemic
eects on the right protected is not disproportionate to the govern-
ment’s objective.30
There is lile doubt that the Government of Canada could
meet the rst two hurdles. The objective to protect the health of the
Canadian population was pressing and urgent, and the measure to
ban travellers exhibiting signs or symptoms of COVID-19 was ratio-
nally linked to this objective. However, it is questionable whether the
government could meet the other two conditions. This measure did
not impair the right in question as lile as possible, as it was both
over- and under-inclusive. It targeted Canadian citizens exhibiting
symptoms that could be indicative of COVID-19 but that could also
be associated with many other conditions, such as other infectious
pulmonary diseases, non-infectious pulmonary diseases, a common
cold, or u. The Government of Canada was asking for an assessment
to be made by airlines representatives who are not medically trained.
As such, they could deny boarding to Canadian citizens who were
not COVID-19 positive and accept on board citizens who could have
been COVID-19 positive but were asymptomatic. This measure also
had the perverse eect of leading some travellers to hide their condi-
tion out of fear of being refused boarding, as has been reported by the
media.31 Finally, critics claim that the transfer of migration manage-
ment to private carriers increases risks of arbitrariness and discrimi-
natory practices (racial proling).32
Contrary to other situations where the measure chosen was the
only means by which the government could meet its pressing and
substantial objectives,33 in this case there were a range of options that
would have allowed for the repatriation of all Canadian citizens. For
example, on regular ights, airlines could have isolated the few citi-
zens exhibiting symptoms. Apart from having to wear masks,34 these
30. R v Oakes [1986] 1 SCR 103, 26 DLR (4th) 200.
31. Dave Seglins, Lisa Mayor & Linda Guerriero “How Sick Canadian Travellers
Are Masking COVID-19 Symptoms to Get Through Airport Screening”, CBC
News (25 March 2020), online: <www.cbc.ca/news/investigates/how-sick-cana-
dian-travellers-are-masking-covid-19-symptoms-to-get-through-airport-screen-
ing-1.5508276>.
32. Anna Tims, “Barred from Flying from a British Airport—Over a Visa He
Didn’t Need”, TheGuardian (22 October 2018), online: <www.theguardian.com/
money/2018/oct/22/airlines-bar-passengers-visa-rules-no-recourse>.
33. AlbertavHuerianBrethrenofWilsonColony, 2009 SCC 37 at para 62.
34. The obligation to wear a face mask during a ight was only imposed on
April 19, 2020, a month after the initial interim order. See Transport Canada,
supra note 20.

VULNERABLE
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passengers could have been distanced by one or two rows from other
passengers, as suggested by some studies.35 As well, special ights
could have been arranged to repatriate these citizens. It is interesting
to note that as early as February 17, 2020, in the second quarantine
order adopted by the government to prevent the spread of COVID-
19, the government provided for measures to bring travellers back on
ights “organized by the Government of Canada or a foreign govern-
ment for the purpose of transporting persons from the foreign country
who have or may have been exposed to that disease.”36 The govern-
ment subsequently did organize ights to repatriate Canadians, but
not, to our knowledge, specically for those exposed to the COVID-19
virus. These alternatives could have been costly and have taken some
time to implement, but that, in and of itself, should not have been
sucient reason to justify infringing Canadian citizens’ fundamental
rights. Admiedly, increased deference should be given to govern-
ments’ choices when, in the midst of a pandemic, it is urgent to act.37
In such moments, the range of what should be considered as reason-
able limits on Charter’s rights might be widened, because of uncer-
tainty as to the eectiveness of various measures taken to protect
public health. However, this still does not shift the onus of establish-
ing the reasonableness of the measure.38 Neither does it justify more
intrusive measures that are no less certain to achieve the desired goal
than other available measures, while increasing uncertainty for those
aected by those measures. Moreover, uncertainty or not, deference
or not, it is particularly important to carefully scrutinize limitations on
rights in emergency situations.
As for whether the eects on the constitutionally protected
rights were disproportionate to the government’s objective, this mea-
sure was preventing vulnerable Canadian citizens from geing back
to their country. Apart from the fact that these citizens needed care if
they were indeed COVID-19 positive, many of them could have suf-
fered from other conditions requiring continued access to medical
35. Michael Laris, “Scientists Know Ways to Help Stop Viruses from Spreading on
Airplanes. They’re Too Late for This Pandemic”, TheWashington Post (29 April
2020), online: <www.washingtonpost.com/local/tracandcommuting/scientists-
think-they-know-ways-to-combat-viruses-on-airplanes-theyre-too-late-for-this-
pandemic/2020/04/20/83279318-76ab-11ea-87da-77a8136c1a6d_story.html>.
36. PC number 2020-0070 (17 February 2020); See Government of Canada, supra
note 19.
37. See Colleen M Flood, Bryan Thomas & Kumanan Wilson, this volume, Chapter C-1.
38. For more on this topic, see CartervCanada(AG), 2015 SCC 5 at para 102.

309
The Right of Citizens Abroad to Return During a Pandemic
care and medications. That access was not a given for anyone sud-
denly forced to remain in another country, especially if this other
country was facing or soon would face a crisis in its health sector.
How can a measure that directly aects the most vulnerable, and that
risks excluding from boarding some citizens who are not COVID-19
positive while allowing others who are, be proportionate?
In writing this, we do not wish to diminish the eort that the
Government of Canada has deployed to bring back citizens, perma-
nent residents, and others stranded abroad. It is estimated that, as
of April 23, 2020, the government had coordinated the repatriation
of approximately 20,000 persons on 160 ights from 76 countries.39
One assumes that a great percentage of those were Canadian citizens.
However, some were also refused boarding. How many were left
behind on the basis that they had symptoms suggestive of COVID-
19 is unknown at this point. Likewise, we do not know how many of
those proved later to be indeed COVID-19 positive, nor do we know
how many passengers were allowed to board and, within 14 days of
arrival, tested positive for COVID-19.
Given its obligations both in international and domestic law,
Canada must ensure at all times that it does not create disproportion-
ate hurdles on the ability of its citizens to exercise their right to return
home. As the current Prime Minister has repeated on numerous occa-
sions in the past: “A Canadian is a Canadian is a Canadian.”40
39. Brian Hermon & Sco McTaggart, “The Canadian Consular Service and
Response to COVID-19” (24 April 2020), online (blog): Library of Parliament,
Hillnotes <hillnotes.ca/2020/04/24/the-canadian-consular-service-and-response-
to-covid-19/>.
40. Faiha Naqvi-Mohamed, “‘A Canadian Is a Canadian Is a Canadian”, Hungton
Post (last modied 20 October 2016), online: <www.hungtonpost.ca/fariha-
naqvimohamed/a-canadian-is-a-canadian-is-a-canadian_b_8337718.html>.