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Author: Gideon Christian Page 1 of 2

LL.B (Lagos), LL.M, PhD (Ottawa). Assistant Professor.
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How an Underscore Sent an Innocent Man to Jail

By: Gideon Christian

Decisions commented on: R v Klayme, 2024 NSPC 4 (CanLII) and R v Klayme, 2026 NSCA 59 (CanLII)

PDF Version: How an Underscore Sent an Innocent Man to Jail

It all began when a mother in Wisconsin, United States, checked her 12-year-old daughter’s phone. What she discovered was horrifying: intimate images and sexually explicit communications with a man who called himself “Jay.” She reported the matter to the police, who seized the phone and extracted 125 messages exchanged through a Kik (social media) messaging account bearing the username fus__ro_dah, with two underscores between “fus” and “ro.”

The Political Threat to the Rule of Law in Canada

By: Gideon Christian PhD

Matter Commented On: Canadian Law Societies’ Ours to Protect Campaign

PDF Version: The Political Threat to the Rule of Law in Canada

Recently, the law societies across Canada came together to launch? Ours to Protect, a national campaign to raise awareness about the importance of the rule of law. In Canada, when we talk about threats to the rule of law, we tend to glance nervously at chaos in other countries, especially the United States. The United States has provided a dramatic study in how quickly respect for legal norms can erode. The Trump White House openly vilified judges who ruled against it – accusing them of abusing their powers and even suggesting they be impeached or prosecuted. Some years back, the same president incited an attack on Congress itself. It was a stark reminder that even free societies can teeter when their leaders flout the rule of law.

A Court Divided: What an Ontario Court Motion Reveals About Race in the Courtroom

By: Gideon Christian

Cases Commented On: Dosu v Human Rights Tribunal of Ontario, 2025 ONSC 6496 (CanLII); Dosu v Human Rights of Ontario, 2025 ONSC 6509 (CanLII)

PDF Version: A Court Divided: What an Ontario Court Motion Reveals About Race in the Courtroom

In a bizarre procedural twist, the Ontario Divisional Court issued two contradictory decisions on consecutive days in the same case. Two written motions for leave to intervene in Dosu v. Human Rights Tribunal of Ontario was sent to two different judges – Justice Sharon Shore and Justice Shaun Nakatsuru – who rendered opposite rulings. Justice Shore dismissed the would-be intervenors; the next day, in a separate ruling, Justice Nakatsuru granted them intervention, setting the stage for what appears to be an embarrassing judicial outcome for the court.

#AI Facial Recognition Technology in the Retail Industry

By: Gideon Christian

Issue Commented On: OIPC Investigation Report 23-02: Canadian Tire Associate Dealers’ use of facial recognition technology, 2023 BCIPC 17

PDF Version: #AI Facial Recognition Technology in the Retail Industry

One summer day in 2023, I entered a Walmart store in Calgary, Alberta, and purchased three standing fans. Upon assembling the fans at home, I discovered that one was malfunctioning. I immediately decided to return it to the store. Armed with my purchase receipt, I walked to the return desk. After a brief wait in line, I presented the defective fan and the receipt to the Walmart staff. To my astonishment, he informed me that the receipt was not necessary and casually remarked, “You bought three of these today, right?” Concealing my surprise, I affirmed. He swiftly processed my refund.

Canada Study Permit Litigation – Critical Analysis of Inconsistent Jurisprudence on Financial Requirement

By: Gideon Christian

Case Commented On: Ocran v Canada (Citizenship and Immigration), 2022 FC 175 (CanLII)

PDF Version: Canada Study Permit Litigation – Critical Analysis of Inconsistent Jurisprudence on Financial Requirement

Early this year, Justice Little of the Federal Court released the much-awaited decision in Ocran v Canada (Citizenship and Immigration), 2022 FC 175 (CanLII). I am not aware of any study permit judicial review litigation that attracted the attention of Canadian immigration lawyers as much as Ocran. The notoriety of this judicial review litigation was based on the fact that it was a test case that the Department of Immigration, Refugee and Citizenship Canada (IRCC) sought to use to obtain judicial approval for its use of the controversial Chinook software in processing of immigration applications. That approval never came. But the fixation on Chinook software caused many immigration lawyers to miss a very important and controversial judicial pronouncement in Ocran relating to the financial requirement for Canadian study permit applications.

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