Canada’s Federal Court has ruled that a citizen of Mexico, who asserted Convention refugee status or a need for protection, failed to establish that the Refugee Appeal Division (RAD) had a duty to advise him to retain counsel.

In Platas Ramos v. Canada (Citizenship and Immigration), 2025 FC 1774, the Refugee Protection Division (RPD) of the Immigration and Refugee Board of Canada (IRB) determined that the applicant was neither a Convention refugee nor a person in need of protection.

The RPD described the determinative issue as the availability of an internal flight alternative (IFA) for the applicant. The RPD concluded that he indeed had a viable IFA in Mérida, Mexico.

In October 2024, the RAD dismissed the applicant’s appeal and upheld the RPD decision. The RAD agreed with the RPD’s

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