Law360 Canada ( September 1, 2021, 5:28 AM EDT) -- Appeals by the Minister from decisions allowing the respondents’ judicial review applications from decisions of the Immigration Division and the Immigration Appeal Division interpreting s. 34(1)(e) of the Immigration and Refugee Protection Act. Section 34(1)(e) provided that permanent residents or foreign nationals were inadmissible on security grounds for engaging in acts of violence that would or might endanger the lives or safety of persons in Canada. The respondents argued s. 34(1)(e) only applied where there was a connection to national security. The Appeal Division found Parliament intended that the provisions of s. 34(1) related to security in a broader sense that included ensuring that individual Canadians are secure from acts of violence that would or might endanger their lives or safety. It noted that elsewhere in the Act, when Parliament intended security of Canada and national security, it used those terms, not the general term security. The Immigration Appeal Division also examined the context of the other inadmissibility provisions in the Act, especially s. 36, which provided for inadmissibility upon conviction of a criminal offence. The Federal Court concluded that the Immigration Appeal Division’s decision was unreasonable. The Federal Court looked at the consequences that flowed from ss. 34 and 36 inadmissibility findings, and concluded that, because somewhat harsher consequences flowed from s. 34 than s. 36, s. 34(1)(e) must have a connection to national security....