The author is A.G., a national of Ethiopia born on 30 December 1975. His application for asylum in Canada has been rejected and he risks being deported to Ethiopia. He claims that, by deporting him, the State party would violate his rights under articles 6 (1), 7 and 9 (1) of the Covenant. The Optional Protocol entered into force for Canada on 19 August 1976. The author is represented by counsel.
On 3 October 2016, the Committee, acting through its Special Rapporteurs on new communications and interim measures, requested the State party not to remove the author to Ethiopia while his case is under examination.
On 27 June 2017, the State party requested the Committee to suspend its consideration of the case until domestic proceedings were concluded, because, on 9 June 2017, the author had submitted a subsequent pre-removal risk assessment application, which involved the consideration of the same allegations of risk and issues that the author had asked the Committee to consider. On 18 September 2017, the author confirmed that he had submitted a second pre-removal risk assessment application and that he was not opposed to the Committee suspending its consideration of the communication. On 23 February 2018, the Committee, acting through its Special Rapporteurs on new communications and interim measures, informed the parties of the suspension of the consideration of the case until the completion of the pre-removal risk assessment procedure.
On 28 May 2019, the State party requested the lifting of the suspension measure, following the completion of the pre-removal risk assessment proceedings. On 15 June 2022, the Committee, acting through its Special Rapporteurs on new communications and interim measures, informed the parties that the suspension measure with regard to consideration of the case had been lifted.
Facts as submitted by the author
The author’s father was of Oromo ethnicity and his mother of Amhara ethnicity. While a student at the Bahir Dar University during the 2000/01 academic year, the author was involved in a strike against government policies. Being of Oromo descent, he supported the Oromo Liberation Front by making financial contributions and helping to raise funds to help imprisoned members. He was however not a registered member of the Front. During the same period, he was arrested while participating in a strike. He was beaten and tortured3 And was released after approximately three weeks’ detention. He was told to sign a declaration that he would not participate in any activities against the Government in the future. After presenting a personal guarantor at the place of detention, he was released.
- No further details are provided by the author. ↩
In 2001, the author fled Ethiopia and eventually arrived in Norway, where he applied for refugee status. Once in Norway, the author stopped contributing financially to the Oromo Liberation Front. His refugee claim was rejected in 2003 or 2004. However, at that time the policy in Norway was not to enforce deportation orders to Ethiopia, so he was allowed to remain in the country for 10 years. The author became a member of two Ethiopian opposition parties with branches in Norway; during the general elections held in Ethiopia in 2005, he was a member of the Alliance Party4 and, around 2009, he became a member of the Ginbot 7 party. As a member of Ginbot 7 in Norway, he paid registration and monthly dues, organized and participated in demonstrations and meetings, collected money and participated in financing activities and distributed flyers.
- In the asylum proceedings, the author declared that he supported the Alliance Party financially “so that it could win the election”. ↩
In 2011, the Norwegian authorities reinstated its policy to carry out deportation orders to Ethiopia, so the author fled the country using a false passport. He went to Iceland, where he was arrested for using a forged passport. He tried to claim refugee status, but, in compliance with the Dublin II Regulation, his claim could not be examined in Iceland. He was released after about 15 days’ detention, but he remained in Iceland for about five to six months before hiding aboard a cargo ship bound for Canada.
On 4 November 2011, the author arrived in Canada and applied for refugee status. However, the proceedings before the Refugee Protection Division were suspended, because the Minister of Public Safety and Emergency Preparedness issued a report asserting that the author was not to be admitted to Canada for security reasons, owing to his participation in both the Oromo Liberation Front and the Ginbot 7 party. On 17 September 2013, an admissibility hearing was held at the Immigration Division of the Immigration and Refugee Board of Canada. The author, represented by counsel, submitted written arguments claiming that the evidence showed that his involvement in the Oromo Liberation Front had been limited to feeling sympathy for the Oromo cause and contributing financially to help families of imprisoned members of the Front. He argued that that was not sufficient to justify his being considered a member of the Oromo Liberation Front within the meaning of section 34 of the Immigration and Refugee Protection Act. Concerning the Ginbot 7 party, the author argued that, although he had clearly testified to his membership and his activities, no evidence proved that the organization had a military wing or was using armed struggle to achieve the overthrow of the Government of Ethiopia.
On 23 January 2014, the Immigration and Refugee Board found that the author lacked credibility and that he was not to be admitted to Canada for security reasons because there were reasonable grounds for considering that he was a member of the Oromo Liberation Front and the Ginbot 7 party and for concluding that the Oromo Liberation Front had engaged in terrorist activities and that Ginbot 7 was an organization with the aim of overthrowing the Government of Ethiopia by force or subversion. Although the author had engaged in neither acts of terrorism nor acts of violence, his affiliation with the organizations led the Immigration Division to conclude that his claim was inadmissible.
The author applied for judicial review, arguing that the Immigration Division had erred in: its assessment of evidence regarding his participation in the Oromo Liberation Front and its characterization of that organization as one engaging in terrorism; characterizing the Ginbot 7 party as an organization described in section 34 of the Immigration and Refugee Protection Act; and in its interpretation of the concept of member within the meaning of the same provision. The author’s application for review was granted, and a hearing took place before the Federal Court. On 28 November 2014, the Federal Court dismissed the author’s application on the grounds that the decision that he was not to be admitted into Canada had been reasonable.
On 23 June 2015, the author’s application for pre-removal risk assessment was refused. Citizenship and Immigration Canada considered that there was insufficient objective evidence to indicate that the author was an official member of the Oromo Liberation Front. It noted that, after the author was arrested in Ethiopia, he was subsequently released on bail; it follows therefore that he was not considered a serious threat to the Government. There was insufficient information to indicate that the author was identified or perceived to be a critic or opponent of the Government of Ethiopia, that he was wanted by the police or that the Ethiopian authorities had a continuing interest in the author or had attempted to contact his family to locate him following his release from prison or following his departure from Ethiopia. As to two letters, dated 11 November 2010 and 14 March 2013, from the Ginbot 7 party, given in support of author’s activities, it assessed the first letter as having low probative value, because it was not signed and, whereas the body of the letter was presented in a clear print, the logo of Ginbot 7 appeared in three places and was blurry. The author alleges that the second letter was never considered, even though it had been properly put before Citizenship and Immigration Canada. While acknowledging the harsh treatment by the Ethiopian authorities of members of the opposition, it concluded that, based on country conditions and the personal circumstances of the author, there was insufficient objective evidence to indicate that he would be a person of interest to the Ethiopian authorities based on his political views or his activities in either Ethiopia or Norway, or that he was wanted by the police.
On 26 January 2016, the author’s application for leave and for judicial review of the pre-removal risk assessment decision was dismissed by the Federal Court.
By letter dated 25 September 2016, the secretary of the division of the Ginbot 7 party in Canada confirmed the author’s active participation in several protests, demonstrations and other Ginbot 7 events in Canada in 2016. By letter dated 26 September 2016, a representative of the Ginbot 7 office in Alexandria, Virginia, United States of America, also confirmed his active membership within the organization.
On 6 February 2018, the author’s subsequent pre-removal risk assessment application was also denied. Citizenship and Immigration Canada found that the evidence presented by the author – much of which was similar to the evidence submitted for his first pre-removal risk assessment application – did not substantiate his claim that he would face a risk of torture, a risk to his life or a risk of cruel and inhuman treatment or punishment upon his return to Ethiopia. In particular, it found that there was insufficient evidence to connect the author’s involvement with the Ginbot 7 party to a personal risk upon return to Ethiopia, noting that there was little information provided to indicate that the author’s actions or the events he attended in 2016 could have been monitored or were under surveillance by the Ethiopian authorities. While acknowledging that the author had claimed that his participation in protests in Canada had been photographed and those photographs made available online, it found a scarcity of information or documentary evidence to corroborate that claim. In addition, there was no information suggesting that the author had been indicted or sentenced in absentia or could be subjected to a lengthy prison sentence upon return to Ethiopia based on his involvement in the Ginbot 7 party. Citizenship and Immigration Canada concluded the assessment by recognizing that, according to the country information on Ethiopia, high level or high-profile members of the opposition were subject to monitoring, harassment and arrest, but noted there was insufficient evidence to indicate that the author was or would be engaged in high-level or high-profile opposition or anti-government activities or perceived to be so engaged by the Ethiopian authorities.
On 15 August 2018, the Federal Court denied the author’s application for leave and judicial review.
Complaint
The author claims that his deportation from Canada to Ethiopia would expose him to a real risk of arbitrary detention, torture, cruel and inhuman treatment and, in the worst case, death, in violation of his rights under articles 6 (1), 7 and 9 (1) of the Covenant. The author also claims that the deportation itself would also constitute a violation of his right to security of person.
The author argues that the conclusion of Citizenship and Immigration Canada, which conducted the pre-removal risk assessment, that he had not established that he was linked to a political organization that would put him at risk in Ethiopia is incompatible with the decision of the Immigration and Refugee Board that the author was not to be admitted to Canada and the subsequent Federal Court decision, in which both entities had found that there were reasonable grounds for considering that he was a member of the Oromo Liberation Front and the Ginbot 7 party. The author also argues that the pre-removal risk assessment decision was erroneous. The insistence on having objective evidence, such as bail papers, medical reports and eyewitness accounts, of events that happened over 15 years ago in Ethiopia was both unreasonable and unrealistic. As to the fact that the author’s family had not been contacted by the Ethiopian authorities regarding his whereabouts, the author notes that his parents have been deceased for several years and that he does not have contact anymore with his only sibling. The author argues that the pre-removal risk assessment is a problematic recourse, mainly because it is decided by civil servants who are employees of Citizenship and Immigration Canada, and not by an independent tribunal.
The author refers to the country conditions in Ethiopia and to reports by non-governmental organizations attesting the serious risk of detention and torture faced by members, suspected members or supporters of the Oromo Liberation Front and the Ginbot 7 party and to the fact that the Government of Ethiopia monitors activities of the diaspora. In this respect, the author notes that the Federal Court decision regarding his asylum application is available online and summarizes his profile and opposition to the Government of Ethiopia. In addition, Canadian authorities met with Ethiopian officials in Ottawa on 1 June 2016 and 26 September 2016 to discuss the author’s deportation to Ethiopia.
State party’s observations on admissibility and the merits
On 28 May 2019, the State party provided its observations on the admissibility and the merits of the communication. It contested admissibility on four grounds: failure to exhaust domestic remedies; incompatibility with the scope of the Covenant, concerning the claim under article 9 (1); failure to substantiate, on even a prima facie basis, that the author would face a real and personal risk of irreparable harm in Ethiopia; and use by the author of his communication to appeal domestic decisions.
The State party observes that the author was eligible to apply for a subsequent pre-removal risk assessment at the end of July 2016, based on a notice about the availability of a pre-removal risk assessment to certain individuals from Ethiopia that had been published on 27 July 2016 on the Citizenship and Immigration Canada public website and on the expiration, on 29 July 2016, of the 12-month pre-removal risk assessment bar. He could have presented the new letters as evidence of risk to domestic decision makers first, before submitting his communication to the Committee. While it is true that, generally, a subsequent pre-removal risk assessment application would not have automatically resulted in a stay of his removal, had his application been accepted for consideration, his removal would have been stayed pending the outcome of that application. Moreover, the author failed to request an administrative deferral of removal. When an applicant makes a request for an administrative deferral of removal, the enforcement officer does not conduct a full assessment of the alleged risks, but rather considers and assesses whether there is new risk-related evidence. If so, removal will be deferred to allow for a full pre-removal risk assessment.
Although the author does not specify how his rights under article 9 (1) have been violated, the State party assumes, based on the totality of his communication, that it is because he believes that he faces a real risk of arbitrary detention in Ethiopia. This allegation is outside the scope of the State party’s obligations under article 9 (1) of the Covenant.
The author lacks credibility. The Immigration Division found discrepancies between the author’s refugee claim form, his personal information form and his testimony at the hearing. The State party also mentions that the author has been inconsistent in describing his family members, uses different iterations and spellings of his name on different documents or occasions5 and shifts the level of his involvement in opposition politics, depending on the audience that he is addressing. For example, during his admissibility hearing, the author downplayed his association with the Oromo Liberation Front, because that could – and did – lead to his being found not admissible to Canada. However, in both pre-removal risk assessment applications and in his communication to the Committee, the author claims active involvement in the Ginbot 7 party, because it allegedly supports his claim that he would be at risk in Ethiopia as someone involved in opposition politics. In addition, the author highlights his Oromo ethnicity, while downplaying his Amharic ethnicity; he was born and spent most of his life in the city of Bahir Dar, which is the capital of the Amhara region of Ethiopia, his first language is Amharic and he does not speak Oromo.
- According to the Canada Border Services Agency, the author has been known by at least seven different names and three different dates of birth. ↩
The State party notes that a web search of the name cited in the Federal Court decision does not result in the retrieval of the court decision to which the author refers. Importantly, the name used on the application for the laissez-passer from the Government of Ethiopia and the name in which the laissez-passer was issued, and therefore presumably the name by which the author is recognized by the Government of Ethiopia, is also different from the name in the Federal Court decision. It is therefore highly unlikely that the Federal Court decision, if found, would be linked to the author.
The author is using the Committee as a tribunal of fourth instance. He relies on the same facts and evidence already considered by domestic decision makers and has not presented any evidence to demonstrate that the conduct of the domestic proceedings or the evaluation of the facts and evidence was manifestly arbitrary or amounted to a denial of justice. He is essentially using his communication to appeal negative decisions in domestic proceedings, thereby asking the Committee to be a tribunal of fourth instance, and his communication therefore is outside the scope of the Committee’s review.
Should the Committee view the author’s communication to be admissible, the State party submits that it is wholly without merit. The author’s alleged fear of Ethiopian officials appears to be based on, at most, two problematic encounters with Ethiopian officials in 2000 and 2001, both of which appear to be isolated incidents tied to the author’s involvement in specific events. There is no evidence that the author was personally targeted by the Government, that Ethiopian officials continued to look for him after he left the country or that there is a warrant or criminal or other charges outstanding against him. There is no evidence that Ethiopian officials would target him in case of his return. In addition, given the change in Government in 2018 and in the country conditions in Ethiopia, it is likely that his past alleged involvement in opposition politics would no longer be considered problematic.
Author’s comments on the State party’s observations on admissibility and the merits
In his comments of 13 August 2022, the author contested the State party’s observations. In particular, he declares that he has exhausted all available and effective domestic remedies that offered a reasonable prospect of redress, because, contrary to the State party’s contention, neither a subsequent pre-removal risk assessment nor an administrative deferral of removal could be considered as either available, effective or as offering a reasonable prospect of redress. He has already made a subsequent pre-removal risk assessment, but to no avail. Moreover, an administrative deferral of removal is a discretionary decision made by the same non-judicial authority that oversees pre-removal risk assessment applications and therefore does not meet the Committee’s definition of an effective remedy.6
- Monge Contreras v. Canada (CCPR/C/119/D/2613/2015), para. 7.3. ↩
The author also submits that, due to the incongruence of the domestic decisions in his case, and especially in the light of the State party’s failure to defend the compatibility of those decisions, he is not using his communication as an appeal, but rather as a complaint pertaining to a denial of justice. He further deems the pre-removal risk assessment decision to be arbitrary and unjust because of the failure to conduct an oral hearing.
The author informs the Committee that, on 29 March 2021, he applied for ministerial relief, but he has not received any update or decision. The application had been pending for nearly a year and five months.7
- In its additional observations of 26 June 2023, the State party confirmed that a decision had not yet been rendered. ↩
The author disagrees with the State party’s statement that country conditions in Ethiopia have improved following the change in Government in 2018. In that sense, he refers to various reports alleging ongoing human rights abuses in Ethiopia.8
- Bertelsmann Stiftung, “BTI 2022 country report: Ethiopia”, 2022, p. 7. Available at https://bti-project.org/en/reports/country-report/ETH; Department of Foreign Affairs and Trade of Australia, “DFAT country information report: Ethiopia”, 12 August 2020, p. 18. Available at https://www.dfat.gov.au/sites/default/files/country-information-report-ethiopia.pdf; Human Rights Watch, “Ethiopia: opposition figures held without charge police deny lawyers, relatives access; ignore bail orders”, 15 August 2020, available at https://www.hrw.org/news/2020/08/15/ethiopia-opposition-figures-held-without-charge; Amnesty International, Annual Report 2020/21, p. 158. Available at https://www.amnesty.org/en/wp-content/uploads/2021/06/POL1032022021ENGLISH.pdf; Danish Immigration Service, “Ethiopia: Political situation and treatment of opposition”, 10 October 2018, p. 4 and 17. Available at https://www.refworld.org/docid/5beadac74.html; and Immigration and Refugee Board of Canada, “Information on the ability of the Ethiopian government to monitor and censor Ethiopian dissidents living in Canada, including scope and type of surveillance, and technology used; treatment of returning dissidents from Canada, including whether particular profiles face greater risks upon return (2014-January 2017)”, response to information request, 2 February 2017, available at https://irb-cisr.gc.ca/en/country-information/rir/Pages/index.aspx?doc=456899. ↩
The author concludes by insisting that the letters attesting to his involvement in the Ginbot 7 party and in political activities within the Ethiopian diaspora, paired with the decision that the author was not to be admitted into Canada, in which it was confirmed that he was a member of the Oromo Liberation Front and the Ginbot 7 party, attest to the direct and personal risk that he faces. This direct and personal link is even more pronounced given the communications between the Ethiopian embassy and Canadian officials to secure a travel document for him, the very goal of which was to deport the author because of the decision that he was not to be admitted to Canada.
State party’s additional observations
On 26 June 2023, the State party submitted additional observations to the Committee in which it renewed its position that the author’s communication was inadmissible in its entirety, in particular because there was no evidence that the author was being sought or had ever been sought out personally by Ethiopian officials since he left the country over two decades ago, in 2001, whether in connection with his low-level involvement with the Oromo Liberation Front during the 2000/01 academic year or his subsequent low-level involvement from overseas with the Ginbot 7 party, with which the author himself declared that he had not been involved for five years.
The State party notes that, in the years that have passed since the author’s second application for a pre-removal risk assessment was denied, on 6 February 2018, the author has not applied for any further pre-removal risk assessments, even though he was eligible to do so beginning on 15 August 2019. Any new pre-removal risk assessment that the author applies for would require Citizenship and Immigration Canada to consider any new risks personal to the author, while accounting for recent developments in country conditions.
Consideration of admissibility
Before considering any claim contained in a communication, the Committee must decide, in accordance with rule 97 of its rules of procedure, whether it is admissible under the Optional Protocol.
As required under article 5 (2) (a) of the Optional Protocol, the Committee has ascertained that the same matter is not being examined under another procedure of international investigation or settlement.
The Committee notes that the State party argued that the author had not exhausted domestic remedies, given that he had not introduced either a subsequent pre-removal risk assessment application, before submitting his communication to the Committee and further pre-removal risk assessment requests, or a request for administrative deferral of removal. The Committee notes that the author did eventually introduce a second set of pre-removal risk assessment proceedings. As to the request for administrative deferral of removal, the Committee has already had the occasion to note that such judicial review is based mainly on procedural issues and does not involve a review of the merits of the case.9 Moreover, where a removal is deferred, it is done to allow for a pre-removal risk assessment,10 whereas the author has had two subsequent applications for such an assessment rejected. Given that the State party did not consider that a number of elements that have not been examined by the domestic authorities to be of relevance, the Committee fails to see sufficient reasons to assume that a further pre-removal risk assessment would have constituted an effective remedy for the author. The Committee therefore considers that the author has exhausted all available domestic remedies, in compliance with the requirements of article 5 (2) (b) of the Optional Protocol.
The Committee takes note of the State party’s argument that the author’s allegations under article 9 (1) are incompatible ratione materiae with the Covenant. In that connection, it notes that the author has not provided any information, evidence or explanation as to how his rights under article 9 (1) would be violated by the State party through his removal to Ethiopia in a manner that would pose a substantial risk of irreparable harm, such as that contemplated under articles 6 and 7 of the Covenant.11 The Committee concludes that this part of the communication is inadmissible pursuant to article 3 of the Optional Protocol.
- N.D.J.M.D. v. Canada (CCPR/C/121/D/2487/2014), para. 10.3; and S.K. v. Canada (CCPR/C/127/D/2484/2014), para. 8.4. ↩
The Committee takes note of the State party’s argument that the author’s allegations under articles 6 (1) and 7 of the Covenant are insufficiently substantiated. However, the Committee is of the view that, for the purposes of admissibility, the complainant has provided sufficient information as to the risk of irreparable harm that he would allegedly face if he were to be returned to Ethiopia and has therefore substantiated his allegations under articles 6 (1) and 7 of the Covenant. Accordingly, the Committee declares the claim admissible and proceeds with its consideration of the merits.
Consideration of the merits
The Committee has considered the communication in the light of all the information made available to it by the parties, in accordance with article 5 (1) of the Optional Protocol.
The Committee takes note of the author’s allegation that the State party would breach its obligations under articles 6 (1) and 7 of the Covenant by deporting him to Ethiopia, because of his alleged activities for the Oromo Liberation Front and for the Ginbot 7 party, coupled with the human rights situation in Ethiopia.
The Committee recalls its general comment No. 31 (2004) on the nature of the general legal obligation imposed on States parties to the Covenant, in which it referred to the obligation of States parties not to extradite, deport, expel or otherwise remove a person from their territory, where there were substantial grounds for believing that there was a real risk of irreparable harm, such as that contemplated by articles 6 and 7 of the Covenant. The Committee has also indicated that the risk must be personal12 and that the threshold for providing substantial grounds to establish that a real risk of irreparable harm exists is high.13 All relevant facts and circumstances must therefore be considered, including the general human rights situation in the author’s country of origin. The Committee further recalls its jurisprudence according to which considerable weight should be given to the assessment conducted by the State party and it is generally for the organs of the States parties to the Covenant to review and evaluate facts and evidence in order to determine whether such a risk exists,14 unless it is found that the evaluation was clearly arbitrary or amounted to a manifest error or a denial of justice.15
- X v. Denmark (CCPR/C/110/D/2007/2010), para. 9.2; A.R.J. v. Australia (CCPR/C/60/D/692/1996), para. 6.6; X v. Sweden (CCPR/C/103/D/1833/2008), para. 5.18; and A.E. v. Sweden (CCPR/C/128/D/3300/2019), para. 9.3. ↩
- X v. Denmark, para. 9.2; X v. Sweden, para. 5.18; and A.E. v. Sweden, para. 9.3. ↩
- Pillai et al. v. Canada (CCPR/C/101/D/1763/2008), para. 11.4; Z.H. v. Australia (CCPR/C/107/D/1957/2010), para. 9.3; and A.E. v. Sweden, para. 9.3. ↩
- Y.A.A. and F.H.M. v. Denmark (CCPR/C/119/D/2681/2015) para. 7.3; Rezaifar et al. v. Denmark (CCPR/C/119/D/2512/2014), para. 9.3; and A.E. v. Sweden, para. 9.3. ↩
The Committee takes note of the State party’s submission that significant weight should be given to the findings of the domestic authorities. The State party argues that the author failed to demonstrate that he was or would be personally targeted by the Ethiopian authorities in case of his return. His account, as stated in his asylum application and during the hearings, was found to lack credibility, including because of a lack of documentary evidence. In this sense, the Committee notes that letters allegedly issued by representatives of the Ginbot 7 party attesting the author’s involvement with the organization were produced before the domestic authorities and duly taken into account by them. While the author manifests his disagreement with the assessment made by the domestic authorities of the letters, the Committee notes that he has not provided specific reasons to show why the Committee should not attach considerable weight to that assessment.
The Committee notes that, while the domestic authorities have accepted that the author was affiliated with the Oromo Liberation Front and the Ginbot 7 party, they considered that his involvement with those two organizations did not amount to such a level that would have attracted the interest of the Ethiopian authorities. While taking note of the reports cited by the author concerning serious human rights violations in Ethiopia, including affecting those affiliated or perceived as being affiliated with those organizations, the Committee observes that the author’s claims were thoroughly examined by the State party’s authorities, which concluded that there was insufficient information to indicate that the author was identified as or perceived to be a critic or opponent of the Government of Ethiopia or was wanted by the police, that there was a warrant or criminal or other charges outstanding against him or that the Ethiopian authorities had a continuing interest in him at present. The author also did not provide any specific information indicating that he would be personally targeted. The Committee notes with concern the human rights situation in Ethiopia,16 but considers that, in an overall appreciation of the various elements brought before it, the author has not shown the existence of a personal risk of irreparable harm to him upon removal to Ethiopia. Without prejudice to the continuing responsibility of the State party to take into account the situation in the country to which the author would be deported, and not underestimating the concerns that may legitimately be expressed with respect to the general human rights situation in Ethiopia,17 the Committee cannot conclude that the decision of the domestic authorities was arbitrary in finding that the author would not face a personal and real risk of treatment contrary to articles 6 (1) and 7 of the Covenant if he were to be deported to Ethiopia.
The Committee, acting under article 5 (4) of the Optional Protocol, is of the view that the author’s forcible return to Ethiopia would not violate his rights under articles 6 (1) and 7 of the Covenant.