Some Thoughts On Why Ontario Is Still Closed, While Other Provinces Are Fully Open

Why is Ontario still completely shut down? Why is there more freedom pretty much everywhere else in North America? Perhaps these bits of information will shine some light on that problem.

In an earlier piece, it was shown that Sarah Letersky and Patrick Harris lobbied the Ontario Government on behalf of AstraZeneca. They were recently at it again, lobbying on behalf of Janssen in June, 2021.

Letersky helped install Ford into power in June 2018, and remained in that Government for a period afterwards. Now, she lobbies that same Government. Quite the conflict of interest.

And as repeated ad nauseum, these “vaccines” are not approved by Health Canada, but instead, have interim authorization under an emergency order. Not at all the same thing. In fact, it’s only legal to distribute because of the emergency declaration.

Describe your lobbying goal(s) in detail. What are you attempting to influence or accomplish as a result of your communications with Ontario public office holders?
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Employment Standards Act: removal of pharmacist exemptions in ESA for improved labour standards. Insurance Act: prohibit restrictive preferred provider networks to protect patient choice in providers. Ontario Drug Benefit Act: sustainable pharmacy funding. Drug Interchangeability & Dispensing Fee Act: advocacy on dispensing fees. Pharmacy Act: scope of practice for pharmacists. Narcotic Safety and Awareness Act: to obtain data from the Narcotic Monitoring System. Health Sector Payment Transparency Act: fair reporting protocols. Drug and Pharmacies Regulation Act: redefinition of where pharmacists can practice. Laboratory and Specimen Collection Centre Licensing Act: for point-of-care and other forms of diagnostic test including for COVID19, and to order/receive lab test results for medication monitoring. Smoke Free Ontario Act: for pharmacy dispensing of medical cannabis. Cannabis Act: for pharmacy dispensing of medical cannabis. Public Hospitals Act: to enable full scope of pharmacist/technician practice. Long Term Care Homes Act: alignment of pharmacy funding with required services to be performed under the act. Emergency Management and Civil Protection Act: for the provision of government-supplied PPE for all front-line pharmacy professionals.

The Ontario Pharmacists Association, much like the Ontario Chamber of Commerce, is subsidized by taxpayers in order to keep its operations going. The OPA has also been involved with Bill 160 and Bill 132, helping to erode transparency among pharmaceutical companies.

Describe your lobbying goal(s) in detail. What are you attempting to influence or accomplish as a result of your communications with Ontario public office holders?
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Seeking legislation, regulation, and policies related to Ontario’s economic competitiveness and prosperity of our membership and their communities. Issues around COVID-19 and advocacy on the impact on Ontario businesses across the province, particularly on supports for business & vaccine & rapid test distribution. Issues surrounding cannabis and advocating for the industry’s growth across the province. Issues surrounding a competitive tax and regulatory environment including pursuing a simplified tax system and improve transparency in regulation. Issues around regional economic development – removal of inter-provincial trade barriers. Issues regarding modernizing energy and infrastructure (specifically broadband infrastructure investment). Issues concerning health care sustainability such as direct and indirect support for research and development as well as the path to economic recovery with regard to COVID-19. Issues relating to a skilled workforce such addressing the skills mismatch, reinventing employment and training services, and ensuring the apprenticeship system becomes more flexible. Issues related economic competitiveness with Ontario’s agri-food sector, leveraging Ontario’s innovation advantage and collaborate with the private sector to fully leverage Ontario’s competitive advantages. Issues related to fiscal position of the province. Issues related to supporting Ontario’s competitive advantage including agri-food, immigration tourism, and lowing electricity rates through investment in sustainable energy infrastructure.

Now, this could just be poor wording, but the Ontario Chamber of Commerce doesn’t actually say that they want the Province reopened. They seem to be pushing for support for businesses forced to be closed.

Of course, it doesn’t help that Rocco Rossi is the head of the Chamber of Commerce. He is a former Head of the Liberal Party of Canada, a former Mayoral Candidate in Toronto, and ran as Candidate for the Ontario Progressive Conservative Party. Rossi is a great example of politics being too close with lobbyists.

The Canadian Federation of Independent Businesses supposedly stands up for the rights of independents, as the name implies. However, it seems to do little beyond parroting official Government tallies.

Unfortunately, Dan Kelly, who runs the CFIB, is more content to virtue signal about taking his own experimental injections, and doing it to his MINOR children.

Walmart is once again lobbying Ford’s Government. Their stated goal: “Lobbying for regulation changes to allow pharmacists to have expanded scope of practice.” Of course, their business interests have grown considerably as of late, since they are considered essential, while so many are not.

See this earlier work on lobbying by big businesses, and how airline lobbying may have impacted inter-Provincial border closures.

Another area that has picked up is the delivery and rideshare industry. One such company is Facedrive, which uses lobbyists tied to the Ontario and Federal Conservative Parties. See Prabhu and Dunlop.

Just a thought, but Facedrive may be contributing to why “conservative” politicians remain so pro-lockdown. It’s good for their bottom line.

Loop Insights Inc. is described as “a Vancouver-based Internet of Things (“IoT”) technology company that delivers transformative artificial intelligence (“AI”) automated marketing, contact tracing, and contactless solutions to the brick and mortar space.” It should come as no surprise that the people lobbying also have lengthy political ties.

So, why is Ontario mostly still shut down? Wild idea, but maybe there are certain people who have financial incentives to keep it that way.

(1) http://lobbyist.oico.on.ca/Pages/Public/PublicSearch/
(2) https://rubiconstrategy.com/
(3) https://www.linkedin.com/in/sarah-letersky/
(4) https://www.linkedin.com/in/patrick-harris-69348726/
(5) https://www.linkedin.com/in/fabienpaquette/
(6) https://www.linkedin.com/in/catherine-paquette-526b0721/
(7) https://twitter.com/CFIB/status/1402405151483248645
(8) https://twitter.com/BNNBloomberg/status/1400170795339497482
(9) https://twitter.com/canadabusiness/status/1399399075640922112
(10) https://twitter.com/CFIB/status/1395133016423505923
(11) https://www.linkedin.com/in/roccorossi/
(12) https://www.linkedin.com/in/stephdunlop/
(13) https://archive.is/WiJc9
(14) https://www.linkedin.com/in/vivek-prabhu-63850120/
(15) https://www.facedrive.com/
(16) https://www.linkedin.com/in/adria-minsky-b8ba9277/
(17) https://archive.is/7yd7R
(18) https://www.linkedin.com/in/carysbaker/
(19) https://archive.is/4fZO3

Twenty Twenty-One Is Now Available

https://www.amazon.ca/dp/B095Y515XK

Twenty Twenty-One is now posted on Amazon, as a Kindle product. It covers a lot of the backstory of the “pandemic” which isn’t being covered by any mainstream outlet. The option of paperback is being looked into.

Yes, it would be nice to give it away, however, research and reporting are very time consuming. Thank you to everyone who has helped support the site, and helped keep this going.

If you have friends or family who would be interested in this kind of information, please share it with them.

The content on Canuck Law is still available for all.

A shoutout to Fred, Andy, and the folks at Civilian Intelligence Network.

DLSPH/UofT Officially Becomes Branch Of WHO, Supports Communism, Anti-White Agenda

Recently, the University of Toronto, Dalla Lana School of Public Health, Centre for Global Health (what a name) officially joined the World Health Organization.

The Pan American Health Organization/World Health Organization (PAHO/WHO) has designated the Centre for Global Health at the Dalla Lana School of Public Health as a WHO Collaborating Centre on Health Promotion.
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PAHO/WHO collaborating centres are institutions such as research institutes, parts of universities or academies, which are designated by the Director-General to carry out activities in support of the Organization’s programmes. Currently there are over 800 WHO collaborating centres (including 183 in the PAHO region) in over 80 Member States working with WHO on areas such as nursing, occupational health, communicable diseases, nutrition, mental health, chronic diseases and health technologies.

This will likely come as a surprise to many, especially those who didn’t know that UofT DLSPH even had a Centre for Global Health. However, it turns out it does. It was announced on March 5, 2020 by Adelsteinn Brown.

Turns out this had been in the works for a while, but the timing is interesting. It’s almost as if a global health crisis was the perfect launch point for it.

Brown, who heads DLSPH, soon became the head of the Ontario Science Table. The OST is completely dominated by academics from the UofT, many of whom have conflicting interests. As for the purposes of the Centre itself:

  • Equity
  • Attention to power and privilege
  • Partnerships guided by mutual benefits, respect and reciprocal learning
  • Interdisciplinary
  • Meaningful engagement with communities
  • Sustainability
  • Effectiveness

For those thinking that everyone will treated equally in this globalist health order, consider the principles. This UofT/DLSPH Centre for Global Health considers equity important, which is equality of outcome, not equality of opportunity. This is Marxism. As for “paying attention to power and privilege”, this is code for hatred against whites, particularly white men.

Equity means the abolishment of private property rights, and of personal wealth, except for the chosen elite. The reasoning goes: isn’t it oppressive to own something when someone else has less?

This idea has been circulated under many different names. The World Economic Forum touts the idea of “replacing shareholder capitalism with stakeholder capitalism”. The idea is much the same.

As for paying attention to power and privilege, who exactly will be blamed for everything when whites are gone? Will the idea be abandoned, or will some other group be on the receiving end?

This partnership may also explain why the Ontario Science Table sees no issue working with CADTH, or Cochrane Canada, 2 more working groups for WHO. There’s also no issue partnering with SPOR Evidence Alliance, which is partially funded by WHO.

The Dalla Lana School of Public Health isn’t just in bed with WHO, it’s part of the WHO. And all of those “Medical Officers” in Ontario with ties to UofT are just the enforcement branch of WHO.

The Centre on Health Promotion is also big on promoting the climate change agenda. If you have family in oil & gas, or you like being able to drive, perhaps consider other options.

It’s worth asking: how come none of this is being reported? Does Ford and his “Conservative” Government not know — or not care — what’s going on? Is the mainstream media completely oblivious to all of it?

Now, it could be argued that DLSPH isn’t really part of the WHO. After all, the Centre for Global Health is just part of it. While true, does anyone expect the UofT to say or do anything that blatantly contradicts it? Will there ever be real policy disagreements?

The “experts” giving guidance on this so-called pandemic claim to be neutral and independent. However, that’s just not the case so often. Here are some examples which include, but are not limited to the UofT DLSPH.

Michael Warner is head of the Canadian Division of askthedoctor.com. Kumar Murty of OST runs a technology company called PerfectCloudIO, which stands to profit from lockdowns. Kwame McKenzie of OST led the research into the 2017 UBI project in Ontario. And on a related note: Trillium Health Partners got a $5 million gift from a company that makes face masks. Abdu Sharkawy makes a small fortune on the speaking circuit. Robert Steiner of OST, an LPC operative, claims to be the brains of PHAC, founded in 2004. Ryan Imgrund shills for lockdowns while his employer fundraises money. Isaac Bogoch is in the UofT club, is part of Ontario’s “Operation Warp Speed”, and pretends to be neutral. Kashif Pirzada has numerous side businesses.

(1) https://www.dlsph.utoronto.ca/who-collaborating-centre-on-health-promotion/
(2) https://www.dlsph.utoronto.ca/institutes/centre-for-global-health/
(3) https://www.dlsph.utoronto.ca/2020/03/05/dlsph-open-dlsph-launches-a-new-centre-for-global-health/
(4) https://www.dlsph.utoronto.ca/2020/02/28/dlsph-welcomes-global-health-powerhouse-nisia-trindade-lima-to-launch-new-centre-for-global-health/
(5) https://www.dlsph.utoronto.ca/wp-content/uploads/2020/02/DLSPHPartnershipGuidelines2018_fordistribution.pdf
(6) DLSPH PartnershipGuidelines 2018 For Distribution

Canada Emergencies Act: Tyranny; No Property Rights; Indemnification; Publication Exemption; Parliamentary Secrecy

https://laws-lois.justice.gc.ca/eng/acts/E-4.5/FullText.html

In case readers here think that the Emergencies Act was a Liberal creation, the answer is no. It came into effect in 1988, under “Conservative” Prime Minster, Brian Mulroney. It looks like the current head, Erin O’Toole, is on board with imposing these types of measures. So much for valuing individual rights.

The actual freedoms that can be stripped away are very similar to the 2005 Quarantine Act, enacted by Liberal Paul Martin. Now, what does this act actually say?

30 (1) While a declaration of an international emergency is in effect, the Governor in Council may make such orders or regulations with respect to the following matters as the Governor in Council believes, on reasonable grounds, are necessary for dealing with the emergency:
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(a) the control or regulation of any specified industry or service, including the use of equipment, facilities and inventory;
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(b) the appropriation, control, forfeiture, use and disposition of property or services;
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(c) the authorization and conduct of inquiries in relation to defence contracts or defence supplies as defined in the Defence Production Act or to hoarding, overcharging, black marketing or fraudulent operations in respect of scarce commodities, including the conferment of powers under the Inquiries Act on any person authorized to conduct such an inquiry;
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(d) the authorization of the entry and search of any dwelling-house, premises, conveyance or place, and the search of any person found therein, for any thing that may be evidence relevant to any matter that is the subject of an inquiry referred to in paragraph (c), and the seizure and detention of any such thing;
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(e) the authorization of or direction to any person, or any person of a class of persons, to render essential services of a type that that person, or a person of that class, is competent to provide and the provision of reasonable compensation in respect of services so rendered;
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(f) the designation and securing of protected places;
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(g) the regulation or prohibition of travel outside Canada by Canadian citizens or permanent residents within the meaning of subsection 2(1) of the Immigration and Refugee Protection Act and of admission into Canada of other persons;

Being allowed to seize or heavily control the means of production basically amounts to socialism. Property rights would end as they can either be entered, or outright seized, without genuine grounds (like getting a warrant). Mobility rights would become non-existent as travel and movement can be stopped almost entirely.

Part (e) comes across as a form of compelled labour. But don’t worry, there will be compensation afterwards.

While this act does mention several different types of emergencies, they are very similar in what freedoms get suspended.

Liability
Marginal note: Protection from personal liability
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47 (1) No action or other proceeding for damages lies or shall be instituted against a Minister, servant or agent of the Crown, including any person providing services pursuant to an order or regulation made under subsection 8(1), 19(1), 30(1) or 40(1), for or in respect of any thing done or omitted to be done, or purported to be done or omitted to be done, in good faith under any of Parts I to IV or any proclamation, order or regulation issued or made thereunder.
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Marginal note: Crown not relieved of liability
(2) Subsection (1) does not relieve the Crown of liability for the acts or omissions described therein and the Crown is liable under the Crown Liability Act or any other law as if that subsection had not been enacted.
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Compensation
Marginal note: Compensation
48 (1) Subject to subsection (2) and the regulations made under section 49, the Minister shall award reasonable compensation to any person who suffers loss, injury or damage as a result of any thing done, or purported to be done, under any of Parts I to IV or any proclamation, order or regulation issued or made thereunder.
.
Marginal note: Release
(2) No compensation shall be paid to a person unless that person, in consideration of the compensation, signs, in a form provided by the Minister, a release of any right of action that the person may have against the Crown as a result of any thing done, or purported to be done, under any of Parts I to IV or any proclamation, order or regulation issued or made thereunder.
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Marginal note: Subrogation
(3) The Crown is subrogated to all rights of any person to whom compensation is paid to recover damages in respect of the loss, injury or damage for which the compensation is paid and may maintain an action in the name of that person or in the name of the Crown against any person against whom the action lies.

No politician or official shall be held personally liable for anything they have done, as long as they acted, or “claim” to have acted in good faith.

Furthermore, if you want any compensation whatsoever, you will be required to sign a waiver of responsibility for every person who make be responsible.

Orders and Regulations
Marginal note: Tabling in Parliament
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61 (1) Subject to subsection (2), every order or regulation made by the Governor in Council pursuant to this Act shall be laid before each House of Parliament within two sitting days after it is made.
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Marginal note: Reference to Committee
(2) Where an order or regulation made pursuant to this Act is exempted from publication in the Canada Gazette by regulations made under the Statutory Instruments Act, the order or regulation, in lieu of being laid before each House of Parliament as required by subsection (1), shall be referred to the Parliamentary Review Committee within two days after it is made or, if the Committee is not then designated or established, within the first two days after it is designated or established.

Typically, orders would have be published, such as in the Canada Gazette. This ensures some transparency, whether or not people agree with the content. However, the Emergencies Act provides an exemption from publication. This is the sort of thing that really demands open discussion.

Parliamentary Review Committee
Marginal note: Review by Parliamentary Review Committee
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62 (1) The exercise of powers and the performance of duties and functions pursuant to a declaration of emergency shall be reviewed by a committee of both Houses of Parliament designated or established for that purpose.
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Marginal note: Membership
(2) The Parliamentary Review Committee shall include at least one member of the House of Commons from each party that has a recognized membership of twelve or more persons in that House and at least one senator from each party in the Senate that is represented on the committee by a member of the House of Commons.
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Marginal note: Oath of secrecy
(3) Every member of the Parliamentary Review Committee and every person employed in the work of the Committee shall take the oath of secrecy set out in the schedule.
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Marginal note: Meetings in private
(4) Every meeting of the Parliamentary Review Committee held to consider an order or regulation referred to it pursuant to subsection 61(2) shall be held in private.
.
Marginal note: Revocation or amendment of order or regulation
(5) If, within thirty days after an order or regulation is referred to the Parliamentary Review Committee pursuant to subsection 61(2), the Committee adopts a motion to the effect that the order or regulation be revoked or amended, the order or regulation is revoked or amended in accordance with the motion, effective on the day specified in the motion, which day may not be earlier than the day on which the motion is adopted.

https://laws-lois.justice.gc.ca/eng/acts/E-4.5/FullText.html

How can there be any accountability, if all of the politicians are sworn to secrecy? Sure, they aren’t really accountable to begin with, but now they have an excuse not to answer.

Now, a report does have to be filed within 1 year of the “emergency” being deemed over. However, that’s cold comfort for those whose livelihoods have been destroyed.

Bill C-21: Redefining Replica Firearms, Turning Them Into Prohibited Weapons

This Bill brings Red Flag and Yellow Flag Laws onto Canadian gun owners, regardless of how law abiding they may be. It also redefines what a “replica” is, and potentially causes more problems.

1. Gun Rights Are Essential, Need Protecting

The freedoms of a society can be gauged by the laws and attitudes they have towards firearms. Governments, and other groups can push around an unarmed population much easier than those who can defend themselves. It’s not conspiratorial to wonder about those pushing for gun control. In fact, healthy skepticism is needed for a society to function.

2. What Criminal Code Currently Says

replica firearm means any device that is designed or intended to exactly resemble, or to resemble with near precision, a firearm, and that itself is not a firearm, but does not include any such device that is designed or intended to exactly resemble, or to resemble with near precision, an antique firearm; (réplique)

The Criminal Code, under Section 84(1), already has a definition for a replica firearm, and it’s a pretty clear one. However, this would make changes to it regarding energy of the discharge, and speed.

3. Changes Bill C-21 Would Make To Code

1 (1) The definition replica firearm in subsection 84(1) of the Criminal Code is replaced by the following:

replica firearm means any device that is designed or intended to exactly resemble, or to resemble with near precision, a firearm that is designed or adapted to discharge a shot, bullet or other projectile at a muzzle velocity exceeding 152.‍4 m per second and at a muzzle energy exceeding 5.‍7 Joules, and that itself is not a firearm, but does not include any such device that is designed or intended to exactly resemble, or to resemble with near precision, an antique firearm; (réplique)

(2) Section 84 of the Act is amended by adding the following after subsection (3.‍1):

Certain firearms deemed to be prohibited devices
(3.‍2) For the purposes of sections 99 to 101, 103 to 107 and 117.‍03, a firearm is deemed to be a prohibited device if
(a) it is proved that the firearm is not designed or adapted to discharge a shot, bullet or other projectile at a muzzle velocity exceeding 152.‍4 m per second or at a muzzle energy exceeding 5.‍7 Joules; and
(b) the firearm is designed or intended to exactly resemble, or to resemble with near precision, a firearm, other than an antique firearm, that is designed or adapted to discharge a shot, bullet or other projectile at a muzzle velocity exceeding 152.‍4 m per second and at a muzzle energy exceeding 5.‍7 Joules.

From this new definition, could air guns, airsoft guns, paintball guns and pellet guns now be considered prohibited weapons? After all, many do “resemble” regular firearms.

By this new definition, many of those guns available for purchase by the general public might qualify. They aren’t designed for the same capacity as real ones. But “exactly resembling, or resembling with near precision” could be very subjective. It also raises the question of what kind of due diligence a person should do to ensure that their gun is not resembling (exactly, or with near precision), a prohibited weapon.

Since these aren’t standard firearms there’s no way to get a license to own them, unless that’s coming next. Is this a way to ban other types of “guns”, or is this just poor wording?

Bill C-21: Yellow Flag Laws To Temporarily (Or Indefinitely) Suspend A Gun License

Red Flag Laws were covered previously. Bill C-21, would also allow for a Chief Firearms Officer to suspend or revoke the license of a person based on “reasonable grounds”. However, the wording is vague, and a reasonable interpretation is that a suspension could be renewed indefinitely. It also calls into question the due process options the person would have.

1. Gun Rights Are Essential, Need Protecting

The freedoms of a society can be gauged by the laws and attitudes they have towards firearms. Governments, and other groups can push around an unarmed population much easier than those who can defend themselves. It’s not conspiratorial to wonder about those pushing for gun control. In fact, healthy skepticism is needed for a society to function.

2. What The Firearms Act Currently Says On This

Refusal to Issue and Revocation
Marginal note: Licences and authorizations
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68 A chief firearms officer shall refuse to issue a licence if the applicant is not eligible to hold one and may refuse to issue an authorization to carry or authorization to transport for any good and sufficient reason.

Marginal note: Registration certificates
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69 The Registrar may refuse to issue a registration certificate, authorization to export or authorization to import for any good and sufficient reason including, in the case of an application for a registration certificate, where the applicant is not eligible to hold a registration certificate.

Marginal note: Revocation of licence or authorization
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70 (1) A chief firearms officer may revoke a licence, an authorization to carry or an authorization to transport for any good and sufficient reason including, without limiting the generality of the foregoing,
(a) where the holder of the licence or authorization
(i) is no longer or never was eligible to hold the licence or authorization,
(ii) contravenes any condition attached to the licence or authorization, or
(iii) has been convicted or discharged under section 730 of the Criminal Code of an offence referred to in paragraph 5(2)(a); or
(b) where, in the case of a business, a person who stands in a prescribed relationship to the business has been convicted or discharged under section 730 of the Criminal Code of any such offence.

Marginal note: Registrar
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(2) The Registrar may revoke an authorization to export or authorization to import for any good and sufficient reason.

Previous Version
Marginal note: Revocation of registration certificate
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71 (1) The Registrar
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(a) may revoke a registration certificate for a prohibited firearm or a restricted firearm for any good and sufficient reason; and
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(b) shall revoke a registration certificate for a firearm held by an individual where the Registrar is informed by a chief firearms officer under section 67 that the firearm is not being used for a purpose described in section 28.

Marginal note: Automatic revocation of registration certificate
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(2) A registration certificate for a prohibited firearm referred to in subsection 12(3) (pre-August 1, 1992 converted automatic firearms) is automatically revoked on the change of any alteration in the prohibited firearm that was described in the application for the registration certificate.

Marginal note:Notice of refusal to issue or revocation
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72 (1) Subject to subsection (1.1), if a chief firearms officer decides to refuse to issue or to revoke a licence or authorization to transport or the Registrar decides to refuse to issue or to revoke a registration certificate, authorization to export or authorization to import, the chief firearms officer or Registrar shall give notice of the decision in the prescribed form to the applicant for or holder of the licence, registration certificate or authorization.

Marginal note: When notice not required
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(1.1) Notice under subsection (1) need not be given in any of the following circumstances:
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(a) if the holder has requested that the licence, registration certificate or authorization be revoked; or
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(b) if the revocation is incidental to the issuance of a new licence, registration certificate or authorization.

Marginal note: Material to accompany notice
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(2) A notice given under subsection (1) must include reasons for the decision disclosing the nature of the information relied on for the decision and must be accompanied by a copy of sections 74 to 81.

Marginal note: Non-disclosure of information
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(3) A chief firearms officer or the Registrar need not disclose any information the disclosure of which could, in the opinion of the chief firearms officer or the Registrar, endanger the safety of any person.

Marginal note: Disposal of firearms
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(4) A notice given under subsection (1) in respect of a licence must specify a reasonable period during which the applicant for or holder of the licence may deliver to a peace officer or a firearms officer or a chief firearms officer or otherwise lawfully dispose of any firearm, prohibited weapon, restricted weapon, prohibited device or prohibited ammunition that the applicant for or holder of the licence possesses and during which sections 91, 92 and 94 of the Criminal Code do not apply to the applicant or holder.

Marginal note: Disposal of firearms — registration certificate
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(5) A notice given under subsection (1) in respect of a registration certificate for a prohibited firearm or a restricted firearm must specify a reasonable period during which the applicant for or holder of the registration certificate may deliver to a peace officer or a firearms officer or a chief firearms officer or otherwise lawfully dispose of the firearm to which the registration certificate relates and during which sections 91, 92 and 94 of the Criminal Code do not apply to the applicant or holder.

Marginal note: Reference
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(6) If the applicant for or holder of the licence or registration certificate refers the refusal to issue it or revocation of it to a provincial court judge under section 74, the reasonable period of time does not begin until after the reference is finally disposed of.

The Chief Firearms Officer or the Registrar already have significant powers in the Firearms Act to suspend or revoke licenses and authorizations for “any good and sufficient” reason”. Of course, this is very vague, and open to interpretation.

There is also the option to refuse to disclose information that could “endanger a person”. In practice, this can mean the person who made such a complaint to get the gun seizure would not have to be confronted by the person they accuse.

This Bill will go even further, and allow for 30 day suspensions of licences. Of course, nothing says that a suspension can’t be renewed — or another one handed out — 30 days later.

3. What Bill C-21 Would Change To Firearms Act

28 The heading before section 68 of the Act is replaced by the following:

Refusal to Issue, Suspension and Revocation

29 Section 68 of the Act is replaced by the following:

Refusal to issue — chief firearms officer
68 (1) A chief firearms officer shall refuse to issue a licence if the applicant is not eligible to hold one and may refuse to issue an authorization to carry referred to in paragraph 20(b) or an authorization to transport for any good and sufficient reason.

Refusal to issue — Commissioner
(2) The Commissioner may refuse to issue an authorization to carry referred to in paragraph 20(a) for any good and sufficient reason.

30 The Act is amended by adding the following after section 69:

Suspension
69.‍1 (1) If a chief firearms officer has reasonable grounds to suspect, on the basis of information that they have collected or received from any person, that the holder of a licence is no longer eligible to hold the licence, they may suspend, in respect of a licence, the holder’s authorization to use, acquire and import firearms for a period of up to 30 days.
.
Notice
(2) A chief firearms officer shall give notice in writing of the suspension to the holder of the licence. The notice shall include reasons for the decision, the nature of the information relied on for the decision, the period of the suspension and a copy of this section and sections 69.‍2 and 70.
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Non-disclosure of information
(3) A chief firearms officer need not disclose any information the disclosure of which could, in their opinion, endanger the safety of any person.
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Termination of suspension
(4) A chief firearms officer shall terminate the suspension at the expiry of the period referred to in subsection (2) or, if they are satisfied that the grounds for the suspension no longer exist, at any time before the expiry of that period. The chief firearms officer shall give notice in writing of the termination of the suspension to the holder of the licence.

Prohibition on use, acquisition and importation
69.‍2 The holder of a licence shall not use, acquire or import firearms while their authorizations to do so are suspended under subsection 69.‍1(1).

31 (1) The portion of subsection 70(1) of the Act before paragraph (a) is replaced by the following:

Revocation of licence or authorization
70 (1) A chief firearms officer may revoke a licence, an authorization to carry referred to in paragraph 20(b) or an authorization to transport — and the Commissioner may revoke an authorization to carry referred to in paragraph 20(a) — for any good and sufficient reason including, without limiting the generality of the foregoing,
(2) Subsection 70(1) of the Act is amended by striking out “or” at the end of paragraph (a) and by adding the following after paragraph (a):
(a.‍1) where the holder of the licence uses, acquires or imports a firearm while their authorizations to do so are suspended under subsection 69.‍1(1); or

32 Section 71 of the Act is amended by adding the following after subsection (2):

Automatic revocation of registration certificate
(3) A registration certificate for a handgun is automatically revoked on the failure of the holder to provide to a chief firearms officer, during the 180 day period referred to in subsection 58.‍01(2), the information required to update the registration certificate for that handgun.

33 Subsection 72(6) of the Act is replaced by the following:

Reference
(6) If the applicant for or holder of a licence or registration certificate refers the refusal to issue it or revocation of it to a provincial court judge under section 74 they shall, within 30 days after referring the matter, deliver to a peace officer or otherwise lawfully dispose of any firearm that they possess. Sections 91, 92 and 94 of the Criminal Code do not apply to the applicant or holder during that time.

Order — return of firearm
(7) If the decision of the chief firearms officer or the Registrar is confirmed, the judge shall, if a firearm was delivered to a peace officer under subsection (6), order the return of the firearm to the applicant for or holder of the licence or registration certificate, in order for the applicant or holder to lawfully dispose of it.

A Chief Firearms Officer can revoke a license for any “good and sufficient” reason. The information can come from anyone, and there is no requirement that the person be named, if done for safety reasons. In short, there is no real right to confront the accuser.

A license can be suspended for 30 days. However, it doesn’t look like there is anything that would prevent necessarily the suspension from being renewed.

While this portion of Bill C-21 is pretty bad, a lot of these rules were already on the books. This just seems to make it easier to issue a 30 day suspension without a real investigation.

4. Challenging Case In Provincial Court

74(2) Limitation period
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(2) An applicant or holder may only refer a matter to a provincial court judge under subsection (1) within thirty days after receiving notice of the decision of the chief firearms officer, Registrar or provincial minister under section 29, 67 or 72 or within such further time as is allowed by a provincial court judge, whether before or after the expiration of those thirty days.

75(3) Burden of proof
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(3) At the hearing of the reference, the burden of proof is on the applicant or holder to satisfy the provincial court judge that the refusal to issue or revocation of the licence, registration certificate or authorization, the decision or the refusal to approve or revocation of the approval was not justified.
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Marginal note: Where hearing may proceed ex parte
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(4) A provincial court judge may proceed ex parte to hear and determine a reference in the absence of the applicant or holder in the same circumstances as those in which a summary conviction court may, under Part XXVII of the Criminal Code, proceed with a trial in the absence of the defendant.

A few things to point out when challenging this is court:

First, there is a 30 day time limit to initiate the proceedings. While the Court “may” allow an extension for applications filed after that, they don’t have to, and there is no guarantee they will. So, be aware of this.

Second, the burden is on the Applicant to prove that the revocation or refusal to issue is unjust. The Firearms Officer doesn’t have to prove anything.

Third, in limited cases, the Judge can proceed ex-parte, which means “without the Parties”. In practice, this will mean the person who applied may not be able to attend.

An overall impression: while this 30 day suspension is certainly bad news, the Firearms Act was already pretty stacked against the rights of gun owners. This certainly doesn’t help.