CAT/C/53/D/520/2012 of persecution for reasons of race, membership in a particular social group, and political opinion. She also sought protection because she faced a risk to life or a risk of cruel and unusual treatment or punishment. The State party notes that she expressly did not seek protection because she faced a danger of torture as defined in article 1 of the Convention. The State party submits that, according to the PIF “narrative”, the complainant decided to ask for refugee protection on the basis of the information from her brother1. She also mentioned, in support of her claim, that she and her grandchildren in Canada had become attached to each other and asked to be allowed to stay in Canada “on a humanitarian basis”. 4.2 On 20 January 2011, the Refugee Protection Division (RPD) of the Immigration and Refugee Board of Canada heard the complainant’s claim. She was represented by legal counsel. She had the opportunity to explain any ambiguities or inconsistencies and respond to any questions that the RPD might have had with regard to her claims. The RPD rendered its decision on 24 January 2011, finding that the complainant was not a “Convention refugee” and not a person in need of protection. In particular, the RPD accepted that the complainant was an unsophisticated person with virtually no formal education, yet concluded that that did not explain the various contradictions in her submissions. The State party further provides several examples of discrepancies identified by the RPD. For example, in her PIF the complainant stated that her husband was arrested on 8 June 2005 and that she was harassed by the police when she went to visit him, while in her oral evidence before the RPD, she stated that her husband was arrested at work and that the police then came to her house and arrested her. With regard to her arrest in 2006, in her PIF, the complainant stated that she and her husband were arrested in 2006 after she had rented a house to two students, while in her oral testimony to the RPD, she stated that about two months after her arrest in 2005, she had travelled to the capital to be with her brother. She stated that she had stayed with her brother until she came to Canada, and never saw her husband again. The RPD noted that the complainant was represented by an experienced lawyer at the time the PIF was filed, and that the lawyer would have been aware that the evidence in the PIF, including the written narrative, would be treated as sworn evidence at the hearing before the RPD. The State party notes that, in any case, the RPD finding that the complainant was not credible was not necessarily determinative of her claim for protection. The RPD found that there was nothing in the complainant’s evidence which would provide a foundation for establishing that she faced a real and personal risk upon return. 4.3 The State party further notes that the complainant made an application for a preremoval risk assessment (PRRA) on 30 September 2011. In her application, the complainant repeated the same version of events as was contained in her PIF. Although the complainant had testified before the RPD that there were significant mistakes in the PIF, neither she nor her counsel sought to present the “correct” version of the facts in her PRRA application. In her application, the complainant relied in part on two letters from persons in Ethiopia which indicated that her husband had been arrested again on account of being in the opposition,2 as well as on several reports by human rights organizations and media articles detailing the ongoing political repression of opponents by the ruling party in Ethiopia. The complainant argued that she was at risk of persecution, torture or risk to life, or of cruel and unusual treatment or punishment by virtue of her perceived affiliation with those in opposition to the Government, her husband’s political involvement, and the fact that she belonged to the Oromo ethnic group. 1 2 4 See para. 2.4 above. Ibid.

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