upper end for such offences. He therefore considers the suggestion that the sentencing judge took his forfeiture of parole into account in reduction of his term to be without foundation. The author maintains that, although revocation of parole continues to be author­ ized not only on conviction for offences for which forfeiture would have automatically ensued before 15 October 1977, but also fohowing conviction of other of­ fences or for some other reason not constituting an of­ fence, the consequences of revocation are less severe under the present law than they were before 15 October 1977. 9.9 Finally, the author's submission of 2 June 1981 provides information that on 1 May 1981 he was again released under the Parole Act, under mandatory super­ vision, which is substantially equivalent to parole. It is argued, however, that as a result of the conditions of his release, he is not a free man and may be re-imprisoned at any time untU late in 1984.' He claims to be entitled to be completely free after 9 June 1981. 9.10 In additional observations, dated 11 June 1981, the author further maintains that he was indeed subjected to the jurisdiction of a judicial authority in connection with the forfeiture of his parole. He states that in accordance with the law in force, he was brought before a Provincial judge, on or about 13 January 1975 (at a time when he was already in custody following his conviction on 13 December 1974) who, in the exercise of his judicial functions, declared that the author's parole was forfeited and issued a warrant, pursuant to section 18 (2) of the Parole Act, for his recommitment to a penitentiary pursuant to section 21 of the Parole Act, then in force. under article 15 (1) he should benefit from this subse­ quent change in the law. 10.2 The Committee further notes that its inter­ pretation and application of the International Covenant on Civil and Political Rights has to be based on the prin­ ciple that the terms and concepts of the Covenant are in­ dependent of any particular national system of law and of all dictionary definitions. Although the terms of the Covenant are derived from long traditions within many nations, the Committee must now regard them as hav­ ing an autonomous meaning. The parties have made ex­ tensive submissions, in particular as regards the mean­ ing of the word "penalty" and as regards relevant Canadian law and practice. The Committee appreciates their relevance for the light they shed on the nature of the issue in dispute. On the other hand, the meaning of the word "penalty" in Canadian law is not, as such, decisive. Whether the word "penalty" in article 15 (1) should be interpreted narrowly or widely, and whether it apphes to different kinds of penalties, "criminal" and "administrative", under the Covenant, must depend on other factors. Apart from the text of article 15 (1), regard must be had, inter alia, to its object and purpose. 10.3 However, in the opinion of the Committee, U is not necessary for the purposes of the present case to go further into the very complex issues raised concerning the interpretation and application of article 15 (1). In this respect regard must be had to the fact that the author has subsequently been released, and that this happened even before the date when he claims he should be free. Whether or not this claim should be regarded as justified under the Covenant, the Commhtee considers that, although his release is subject to some conditions, for practical purposes and without prejudice to the cor­ rect interpretation of article 15 (1), he has in fact ob­ tained the benefit he has claimed. It is true that he has maintained his complaint and that his status upon release is not identical in law to the one he has claimed. However, in the view of the Committee, since the poten­ tial risk of re-imprisonment depends upon his own behaviour, this risk cannot, in the circumstances, repre­ sent any actual violation of the right invoked by him. 10.1 The Human Rights Committee notes that the main point raised and declared admissible in the present communication is whether the provision for the retroactivhy of a "hghter penahy" in article 15 (1) of the Cov­ enant is apphcable in the circumstances of the present case. In this respect, the Committee recahs that the Canadian legislation removing the automatic forfeiture of parole for offences committed while on parole was made effective from 15 October 1977, at a time when the aheged victim was serving the sentence imposed on him under the earher legislation. He now claims that 10.4 For the reasons set"out in paragraph 10.3, the Human Rights Committee, acting under article 5 (4) of the Optional Protocol to the International Covenant on Civil and Political Rights is of the view that the present case does not disclose a violation of the Covenant. ' According to a correction submitted by the State party (19 February 1982), Mr. Van Duzen's combined terms have been calculated to expire on 5 January 1985. 121