CAT/C/61/D/687/2015 allegations. In that connection, the State party submits that the complainant now alleges that he was a victim of torture because he tried to get justice against terrorists and is a witness in the fight against the terrible impunity and brutal killings by Sunni terrorist organizations in Pakistan, but has provided no evidence to support this allegation. The State party also submits that this allegation differs considerably from what the complainant said in his initial complaint to the Committee, in addition to being different from what he testified before the Refugee Protection Division and wrote in his pre-removal risk assessment application. The complainant has never alleged that he witnessed any brutal killings, let alone brutal killings by Sunni terrorist organizations, in Pakistan. In addition, he previously claimed to have had contact with only one Sunni organization in Pakistan, a local branch of Sipah e Sahaba. Furthermore, he previously alleged that he had been assaulted by members of that local branch because he had intervened in a physical altercation between his Christian employee and some members of the local branch. 6.3 In regard to the complainant’s claims that his family is “forced to suffer the same torture and harassment” by the group in Pakistan, the State party submits that he provides no evidence to support this statement, which is different from the allegations contained in his initial complaint, where he stated that he had shifted his family to a safe location with relatives prior to coming to Canada. The State party submits that these new allegations of risk that the complainant is now advancing should cause the Committee to be very concerned about the credibility of the communication as a whole. 6.4 The State party adds that the complainant makes numerous inaccurate and/or misleading statements, seemingly to bolster his complaint. For instance, it considers that the complainant misrepresents the facts and findings from Kaur v. Canada (Minister of Citizenship and Immigration) (see para. 5.3 above) when claiming that the Kaur case is a representative of domestic tribunals in Canada having “recognized the type of abuse still taking place” in Pakistan “and why it is taking place”. He also claims that the Kaur case contains “facts that are quite similar” to his own case. The State party notes that the Kaur case is quite different from the complainant’s situation: it involves allegations with respect to India, not Pakistan, it addresses police abuses, not the actions of a terrorist organization, and it involves the persecution of human rights advocates, which is not descriptive of the complainant. 6.5 In regard to the complainant’s statement that the State party’s decision makers rejected pertinent evidence without reason and that the State party’s initial submission is contrary to fundamental justice, the State party asserts that the complainant has provided no evidence to support his claims that the manner in which his allegations were analysed by domestic decision makers was clearly arbitrary or amounted to a denial of justice. The State party adds that the complainant has not provided any specific examples of “arbitrariness” or “denial of justice”. 6.6 The State party also argues that the complainant provides no evidence to support his allegation that he faces any risk from security and intelligence agencies of Pakistan, or from multiple Sunni terrorist organizations or multiple generic Pakistani terrorist organizations. The most that can be said is that the complainant was assaulted by members of the local branch of Sipah e Sahaba, which is a non-State actor. The State party reiterates that the complainant has provided no evidence to substantiate that any pain that he may have suffered was “inflicted by or at the instigation of or with the consent or acquiescence of a public official or other person acting in an official capacity”. 6.7 The State party also observes that the complainant has provided no evidence to substantiate his claim that terrorist organizations in Pakistan are supported by the Sunnimajority Government, through its intelligence agency ISI. Nor has he presented evidence to support his allegation that the Government of Pakistan is reluctant to take action against terrorist organizations in Pakistan. 6.8 The State party considers that the complainant’s allegations regarding current country conditions are not substantiated: he seems to rely on a Canadian website, www.travel.gc.ca, to substantiate his allegations regarding the current situation in Pakistan, 9

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