CAT/C/61/D/687/2015 blasted a Shia mosque and killed 40 Shia; and (d) on 13 February 2015, the Taliban blasted a Shia mosque and killed 20 Shia and injured dozens. In that connection, the complainant informs the Committee that the Government of Canada, through its department for foreign affairs and international trade, issued travel advice in respect of Pakistan warning against all non-essential travel to Pakistan due to the serious threats.11 5.3 The complainant explains that the security situation remains fragile and unpredictable and that the terrorist threat remains very high. He adds that heightened security measures are currently in place throughout the country and that checkpoints may be set up without warning. He refers to the 2015 United States Department of State report on religious freedom in Pakistan, in which it is stated that sectarian violence and discrimination against religious minorities continued. 12 He submits that the Government’s respect for and protection of the right to religious freedom remains poor and its limited capacity and will to investigate or prosecute the perpetrators of attacks against religious minorities allows the climate of impunity to persist, hence the threat to his life in Pakistan is real and genuine. The complainant states that the domestic tribunals in the State party have recognized the type of abuse that is still taking place in Pakistan and why it is taking place. He refers to the judgment of the Federal Court in Kaur v. Canada (Minister of Citizenship and Immigration)13 and submits that the facts are quite similar to his case. 5.4 The complainant adds that the general position of the Office of the United Nations High Commissioner for Refugees on the issue of internal flight alternatives is that when the persecutors are agents of the State, there is no valid internal flight alternative.14 Many times, victims of torture witness the forced disappearance of immediate family members and they are at risk anywhere in Pakistan. The complainant submits that the internal flight alternative is not a safe option for him, as Sunni hardliners are eagerly looking for him and they are spread all over Pakistan. 5.5 The complainant maintains that the State party is wrong to say that Canadian legal procedures provide a real guarantee against a violation of article 3 of the Convention. He reiterates that there is clearly a substantial risk of torture for him, that he has clear marks of torture on his body and that he has doctor’s letters from Pakistan confirming the torture he suffered in Pakistan.15 He claims that his case clearly shows the insufficiency of the existing Canadian procedures to avoid violations of the fundamental rights of torture victims. He has submitted strong evidence, such as medical reports, affidavits and photographs, regarding the torture, ill-treatment and threat to the lives of himself and his family in Pakistan. 5.6 The complainant considers that there are clear problems with the effectiveness of the State party’s procedures. Regarding the State party’s argument that he still has the possibility of making an application on humanitarian and compassionate grounds, he submits that the procedure does not provide for any stay of removal unless it is approved, which may take three to four years. The complainant argues that he has established a prima facie case, and that the manner in which his evidence has been analysed by the State party is clearly arbitrary and the way it is considered amounts to a denial of justice. State party’s observations on the complainant’s comments 6.1 By note verbale of 17 January 2017, the State party submitted its observations on the complainant’s comments. The State party reiterates its arguments and concludes that the communication is inadmissible, and argues that State protection and an internal flight alternative are available to the complainant, and that his allegations are therefore without merit. 6.2 The State party considers that certain allegations contained in the complainant’s supplemental submission are inaccurate, misleading, or inconsistent with his previous 11 12 13 14 15 8 The complainant does not provide the source of information. Available from https://www.state.gov/documents/organization/256527.pdf. 2005 FC 1491, available from http://canlii.ca/t/1m0m6. The complainant does not provide any reference. The complainant includes some pictures, allegedly of him with injuries, in his complaint.