Litigation Support

Toussaint Petition to UN Human Rights Committee and Follow-up

UN petition materials, follow-up proceedings, and ongoing Canadian litigation arising from the Human Rights Committee decision in Toussaint v Canada.

Historic Victory at the UN Human Rights Committee and Ongoing Litigation in Canada

The right to life and non-discrimination of irregular migrants in access to essential health care

KEY DOCUMENTS

The famous 2018 decision of the UN Human Rights Committee:

Toussaint v Canada CCPR/C/123/D/2348/2014 (30 August 2018)

Canada's Response to the Committee's Decision, refusing to comply with it.

Canada's Response to the UN Committee's Decision

The Ontario Superior Court decision of August 17, 2022 of Perell J. dismissing Canada's Motion to Strike Nell Toussaint's Challenge to Canada's Refusal to Implement the UN Human Rights Committee's Decision.

Toussaint v. Canada (Attorney General) 2022 ONSC 4747

Order of Justice Perell August 17, 2022

Toronto Star Aug 19th, 2022

Sadly, Nell Toussaint passed away on January 9, 2023 but her Case is Proceeding

Bruce Porter, Some Reflections on Nell Toussaint: July 14, 1969 - January 9, 2023, The Person Behind the Historic Human Rights Case

Nicholas Keung, She went from undocumented to undeniable. Advocate whose fight against Canadian government reached the UN remembered as an inspiration

Nell Toussaint Honoured for Black History Month February 2024

Key Documents - From Most Recent

UN Human Rights Committee Concluding Observations (March 23, 2026) CCPR/C/CAN/CO/7

SRAC and ESCR-Net Submissions for the Periodic Review

Ongoing Action in the Ontario Superior Court following Motion to Strike

Ann Toussaint, Appointed Representative of the Estate of Nell Toussaint, Deceased, for the Purposes of this Proceeding v. Attorney General of Canada

Fresh Amended Statement of Claim

Statement of Defence - Canada

Motion Record of Ann Toussaint

Endorsement Order of Justice Vermette

Order of Justice Vermette Adding Ann Toussaint

Endorsement Order of Justice Papageorgiou

CCPI Coalition Case Conference Brief May 17, 2024

Defendant's Case Conference Brief (May 22, 2024)

Brief of Pleadings, Endorsements and Orders (as of May 28, 2024)

CCPI Coalition Motion Record Leave to Intervene

CCPI Coalition Factum Leave to Intervene

CCPI Coalition Compendium

CCPI Coalition List of Authorities

Amnesty International-ESCR-Net Factum Leave to Intervene

AG Factum Response to AI-ESCR-Net and CCPI Coalition

Reconsideration Decision on Migrant Workers Coalition Intervention (March 31, 2025)

Amended Decision of Papageorgiou J on Interventions and Mediation (March 31, 2025)

Motion on Mandatory Mediation

Plaintiff Motion Record on Mandatory Mediation

Plaintiff Factum on Mandatory Mediation

AG Factum re Mandatory Mediation and Deemed Undertaking

Plaintiff's Reply Factum on Mandatory Mediation

Ontario Court of Appeal Decision of February 23, 2023 on jurisdiction and limitations order

Toussaint v Canada (Attorney General), 2023 OCA 117

Follow-Up Action to Encourage Canada to Implement the Views at the UN and in Canada

UN Human Rights Committee Evaluates Canada's Response to Views CCPR/C/123/2 p. 13 and decides to keep trying to engage with Canada

Canada Responds to Further UN Human Rights Committee Follow-Up Requests refusing to implement the Views (6 April 2022).

Complainant's Submissions to UN Human Rights Committee on Follow-up (March 23, 2023)

AI-ESCR-Net Submissions on Follow-up to UN Human Rights Committee (March 23, 2023)

Letter from Human Rights and Health Organizations and Experts to Canada Urging Implementation of the Human Rights Committee's Views (January 22, 2024)

Canada's Response to Universal Periodic Review Recommendation 180 on access to health care: "Undocumented migrants in Canada do not qualify for the Interim Federal Health Program (IFHP) or provincial/territorial health insurance." (March 15, 2024)

Here are the key documents in the Motion to Strike, leading to the Decision of Justice Perell

AG Canada Motion to Strike the Statement of Claim (amended)

AG Canada Factum Motion to Strike

CCPI Coalition Factum - Motion to Strike

Amnesty International & ESCR-Net Factum Motion to Strike

Colour of Poverty Coalition Factum Motion to Strike

Canadian Civil Liberties Association Factum Motion to Strike

Plaintiff Factum Motion to Strike

AG Canada Reply Factum

Toussaint v. Canada (Attorney General) 2022 ONSC 4747

The Petition to the UN Human Rights Committee (Under the Optional Protocol to the ICCPR)

After having exhausted domestic remedies before Canadian courts (see Toussaint Litigation 2009-2018) Nell Toussaint filed a petition to the UN Human Rights Committee alleging violations of the right to life in article 6 of the International Covenant on Civil and Political Rights, and the right to non-discrimination under article 26.

On August 7, 2018 the Human Rights Committee issued its historic decision, finding that Canada had violated Nell's right to life and non-discrimination and that the government must take necessary measures to ensure that no one is denied access to essential health care because of irregular immigration status. This is the first decision of a UN treaty monitoring body to consider access to health care for irregular migrants as a right to life issue.

Executive Summary of the Petition

Petition: Nell Toussaint v Canada HRC No 2348-2014

Canada's Response on Admissibility

Author's Comments on Admissibility

Canada's Response on Merits

Author's Comments on Canada's Submissions

Amnesty International's Opinion in Support of the Author

ESCR-Net's Opinion in Support of the Author

Canada's Supplementary Response

Author's Response to Canada's Supplementary

Opinion Letter of Constitutional and Health Law Experts

The Human Rights Committee's decision:

Toussaint v Canada CCPR/C/123/D/2348/2014 (30 August 2018)