Can a small business owner in Guatemala who is targeted by extortionists acting in concert with police authorities be considered a refugee?
Canada (Federal), Canada
The following excerpt is from Randhawa v. Canada (Minister of Citizenship and Immigration), 1998 CanLII 7370 (FC):
Furthermore, in Soberanis v. Canada (Minister of Citizenship and Immigration)4 Madame Justice Tremblay-Lamer held that small business proprietors in Guatemala who had been victimized by extortionists acting in concert with police authorities could not be considered as a particular social group as recognized under the definition of Convention refugee.
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