Date: 20071206
Docket: IMM-4263-07
Citation: 2007 FC 1280
Ottawa, Ontario, December 6,
2007
PRESENT: The Honourable Mr. Justice Shore
BETWEEN:
HERICK
GAY
Applicant
and
THE MINISTER OF CITIZENSHIP
AND IMMIGRATION
Respondent
REASONS FOR JUDGMENT AND JUDGMENT
INTRODUCTION
[1]
A
Visa
Officer’s failure to consider and include the Chinese properties in
her calculation of the applicant’s assets constitutes a reviewable error. It is
not a breach of procedural fairness; it is a failure to consider evidence. If
material to the result, the decision must be set aside. (As reflected
upon by Carolyn Layden-Stevenson of the Federal Court in Zheng v. Canada (Minister of
Citizenship and Immigration), 2002 FCT 1115, [2002] F.C.J. No. 1478
(QL), para. 15.)
JUDICIAL PROCEDURE
[2]
The
Applicant seeks a judicial review of the decision of a Designated Immigration
Officer of the Canadian Embassy in Port-au-Prince, Haiti, refusing the
Applicant’s application for permanent residence to Canada made pursuant to
subsection 11(1) of the Immigration and Refugee Protection Act, S.C.
2001, c.27 (IRPA).
FACTS
[3]
The
Applicant, Mr. Herick Gay, is a citizen of Haiti, presently living in Port-au-Prince. Accountant by
profession, he applied on May 10, 2005, for permanent residence under the
skilled worker category at the Canadian Embassy in Port au-Prince, Haiti. (Applicant’s Record,
Affidavit of Herick Gay, Tab 3, p. 8.)
[4]
On
July 11, 2005, Mr. Gay forwarded proof of his financial situation to the
Canadian Embassy in Haiti, claiming US $19,592.10
as his available financial resources. (Applicant’s Record, Affidavit of Herick
Gay.)
[5]
A
letter from the Canadian Embassy in Haiti, dated March 22, 2006, was sent to the
Applicant requesting that he provide evidence of the availability of his
financial resources in the amount of CDN $10,168.00, for the purpose of establishment
in Canada for his file to be
finalized. (Affidavit of Edwige Guirand, paras. 5-6; CAIPS (Computer Assisted
Immigration Processing System) notes March 14, 2006.)
[6]
On
April 10, 2006, Mr. Gay, by means of a personal representative, forwarded to
the Canadian Embassy in Haiti a certified copy of a
property deed, showing his title to the land, a statement of his net assets and
new bank statements. The financial evidence provided at this time had a total
value of approximately CDN $22,000.00. (Affidavit of Edwige Guirand, paras.
6-8, Exhibit “B”, “C”, “D” and “E”; Applicant’s Record, Affidavit of Herick
Gay, para. 6, Exhibit “C” and “D”.)
[7]
On
June 5, 2006, Mr. Gay received the decision of the Designated Immigration
Officer of the Canadian Embassy in Port-au-Prince, Haiti, refusing Mr. Gay’s
application for permanent residence to Canada pursuant to paragraph 76(1)(b) of the Immigration
and Refugee Protection Regulations, SOR/2002-227 (Regulations). (Affidavit
of Edwige Guirand, para. 9.)
[8]
On
June 5, 2006, Mr. Gay, assisted by his representative, Mr. Tim Morson, asked
the Canadian Embassy’s Immigration Director in Port-au-Prince, Haiti, to re-open the file
and to have it re-examined by a second Immigration Officer. It was believed that
an error had been made in respect of the documents which clearly demonstrated
that Mr. Gay had the sufficient funds to be considered a Federal Skilled Worker
as per paragraph 76(1)(b) of the Regulations. (Applicant’s Record,
Affidavit of Herick Gay, para 10, Exhibit “F”.)
[9]
On
June 7, 2006, the Canadian Embassy’s Immigration Director confirmed that the
file had been properly determined and that no errors had been made.
(Applicant’s Record, Affidavit of Herick Gay, para. 11, Exhibit “G”.)
[10]
On
June 19, 2006, Mr. Gay’s representative, sent a letter to the Director-General,
Case Management Branch of Citizenship and Immigration Canada, requesting that
the file be re-opened for the purpose of re-examination by a second Immigration
Officer as it was believed that an error in fact and in law had been made.
(Applicant’s Record, Affidavit of Herick Gay, para. 19, Exhibit “H”.)
[11]
On
July 6, 2006, the Case Management Branch of Citizenship and Immigration Canada
confirmed that the Officer’s decision was correct and final and invited Mr. Gay
to seek leave for judicial review if he believed that there was an error in
fact and in law.
[12]
Mr.
Gay argued that the Officer erred in failing to take into consideration all of
the relevant evidence which he presented to rebut the presumption of
inadmissibility to Canada. Mr. Gay specified that
the Officer made no reference to his evidence in the decision.
[13]
The
Respondent argued that Mr. Gay raised no arguable case:
·
the
Officer considered the Applicant’s financial documentation (CAIPS notes);
·
the
Officer informed the Applicant of the concerns regarding his settlement funds
(i.e. that he would have to provide proof that the required funds were
available);
·
the
Officer reasonably decided not to consider the Applicant’s land assets in the
calculation of his settlement funds, as the Applicant did not establish that
this property amounted to funds that were available, transferable and
unencumbered by debts or other obligations – as required by subsection 76(1) of
the Regulations.
DECISION UNDER REVIEW
[14]
The
Visa Officer concluded that Mr. Gay was inadmissible to Canada as he did not have the
transferable and available unencumbered funds required pursuant to subsection
76(1) of the Regulations.
[15]
The
Officer determined that Mr. Gay disposed of CDN $7,501.30; and, therefore, did
not meet the CDN $10,168.00 required for a person to establish himself in Canada.
LEGISLATION AND POLICY
GUIDELINES
[16]
Subsection 11(1) of the IRPA reads as
follows:
|
Application
before entering Canada
11.
(1) A foreign national must, before entering Canada, apply to an officer for a visa or for any other document
required by the regulations. The visa or document shall be issued if,
following an examination, the officer is satisfied that the foreign national
is not inadmissible and meets the requirements of this Act.
|
Visa et documents
11. (1) L’étranger doit,
préalablement à son entrée au Canada, demander à l’agent les visa et autres
documents requis par règlement, lesquels sont délivrés sur preuve, à la suite
d’un contrôle, qu’il n’est pas interdit de territoire et se conforme à la
présente loi
|
[17]
The
relevant provisions of the Regulations read as follows:
|
Applications
10. (1) Subject to paragraphs
28(b) to (d), an application under these Regulations shall
(c) include all information and
documents required by these Regulations, as well as any other evidence
required by the Act;
…
Federal Skilled Worker Class
76. (1) For the purpose of determining whether a skilled
worker, as a member of the federal skilled worker class, will be able to
become economically established in Canada, they must be assessed on the basis of the following criteria:
…
(b) the skilled worker must
(i)
have in the form of transferable and available funds, unencumbered by debts
or other obligations, an amount equal to half the minimum necessary income
applicable in respect of the group of persons consisting of the skilled
worker and their family members, or
|
Demandes
10. (1) Sous réserve des alinéas 28b) à d),
toute demande au titre du présent règlement :
[...]
c) comporte les renseignements et
documents exigés par le présent règlement et est accompagnée des autres
pièces justificatives exigées par la Loi;
[...]
Travailleurs qualifiés (fédéral)
76. (1) Les critères ci-après indiquent que
le travailleur qualifié peut réussir son établissement économique au Canada à
titre de membre de la catégorie des travailleurs qualifiés (fédéral) :
[...]
b) le
travailleur qualifié :
(i) soit
dispose de fonds transférables — non grevés de dettes ou d’autres obligations
financières — d’un montant égal à la moitié du revenu vital minimum qui lui
permettrait de subvenir à ses propres besoins et à ceux des membres de sa
famille,
|
[18]
Justice Elizabeth Heneghan of the Federal
Court determined in Hernandez v. Canada (Minister of Citizenship and Immigration), 2004 FC 1398, [2004]
F.C.J. No. 1698 (QL):
[16] Section 8.2 of the
OP6 Manual is also relevant as it provides that the requirement to provide
"all information and documents" as stipulated by section 10(1)(c),
must be carried out before an officer will undertake any substantive
consideration of an application. In the event that an application does not meet
this requirement, the officer is to advise the applicant that no further
processing shall be completed until all supporting documents have been
submitted.
ISSUE
[19]
Did
the Designated Visa Officer err in fact or law by making a decision on the face
of the record based on inferences which were unreasonable? (This issue requires
examination of bank statements and title to property.)
STANDARD OF REVIEW
[20]
With
respect to the discretionary decision of a Visa Officer, the appropriate
standard of review is reasonableness simpliciter. Where statutory
discretion has been exercised in good faith and, where required, in accordance
with the principles of natural justice, and where reliance has not been placed
upon considerations irrelevant or extraneous to the statutory purpose, the
courts should not interfere. (Yin v. Canada (Minister of
Citizenship and Immigration), [2001] F.C.J. No. 985 (T.D.) (QL), Maple
Lodge Farms Ltd. v. Canada, [1982]
2 S.C.R. 2.)
ANALYSIS
[21]
The
Officer erred by failing to refer to all the documentation submitted by Mr. Gay
pertaining to his financial situation. Mr. Gay submitted bank statements and
evidence of property ownership equivalent to a combined value of approximately
CDN $22,000.00. Mr. Gay also notified the Canadian Embassy, by way of letter,
dated April 10, 2006, and signed by his representative, of his intention to
sell his property once his application had been accepted in principle.
(Applicant’s Record, Affidavit of Herick Gay. Tab 6, para. 6, Exhibit “C” and
“D”; see Summary of Applicant’s Financial Situation annexed hereto as Annex “A”.)
[22]
There
is no indication that the Officer considered the property deed, nor the letter
of April 10, 2006. Justice Jean-Eudes Dubé of the Federal Court noted in Ioda v. Canada (Minister of
Employment and Immigration), [1993] F.C.J. No. 605 (QL), that a failure to
demonstrate documentary evidence in reaching a decision is an error on the part
of the Tribunal:
[16] As to the documentary evidence, in the instant
case there is simply no way of knowing whether the tribunal had due regard to
that evidence in reaching its decision. The reasons do not show that it
considered any of the voluminous documentary evidence submitted concerning
conditions in Latvia and their effect on persons in Ioda's "particular social
group" as a result of her mixed marriage.
…
[18] A fortiori, in my view, the second level tribunal is also in error
in failing to consider documentary evidence which might further substantiate
the claims of credible claimants. In the circumstances it is impossible for the
court to be satisfied that the tribunal considered the evidence properly before
it.
[23]
The
Officer, in her Affidavit, states at paragraph 3: “a printout of the notes
taken by me while assessing the Applicant’s file is attached to this affidavit
as Exhibit ‘A’. These CAIPS notes, along with my decision letter, comprise my
reasons for decision in this matter”. Mr. Gay, however, states that he did not
receive a copy of the CAIPS notes, which, together with the decision letter,
comprise the reasons for the Officer’s decision; and, therefore, Mr. Gay
clearly did not receive all, or the integral reasons for the decision.
[24]
The
Respondent states, at paragraphs 14 and 15 of his Memorandum of Argument, that Mr. Gay
was sent a “fairness letter”, dated March 22, 2006, in which he was informed that
the information he had provided with respect to his settlement funds was
“insufficient”. The word “insufficient” is nowhere in the letter of March 22,
2006. The letter simply states that in order to continue processing the
application, additional documentation is required and then lists the documents
requested, among them, proof of financial capacity for settlement in Canada. (Applicant’s Record,
Affidavit of Herick Gay, Letter of March 22, 2006, Exhibit ‘B’; Applicant’s
Reply Memorandum of Argument, para. 8.)
[25]
The
Respondent states at paragraph 17 of his Memorandum of Argument that he “considered
all of the Applicant’s financial documentation, but reasonably decided not to
take the Applicant’s estimated value for his land into account in this
calculation, because he did not establish that this asset was available,
transferable and unencumbered by debts or other obligations…”
[26]
Nowhere
in the CAIPS Notes, prior to March 22, 2006, did the Officer formulate any
concerns about Mr. Gay’s ability to satisfy the financial criteria. These
concerns appeared for the first time on April 13, 2006, wherein the Officer
notes: “requérant ne rencontre pas les exigences financières pour son
immigration au Canada”, and further notes: “nous ne pouvons pas comptabiliser
les 2 terrains dont requérant est propriétaire”. Stating that the value of the two pieces of
land could not be calculated, the Officer did not provide Mr. Gay with the
opportunity to provide more complete information in order to address the
concerns.
[27]
Despite
Mr. Gay’s letter, dated July 11, 2005, in which he provided a summary of his
financial situation for which he evaluated one piece of land to be worth US $14,000.00,
the Officer only raised her inability to calculate the value of both pieces of
land for the first time on April 13, 2006. (Reference is made to Annex “A”
of this decision.)
[28]
Since
the Officer only formulated her concerns about Mr. Gay’s ability to meet the
financial capacity criteria, the day that the application was refused, it is
clear and unambiguous that she never conveyed her concerns to Mr. Gay in this
regard; therefore, Mr. Gay was never afforded an opportunity to respond to this
issue.
[29]
Even
if the Officer had refused to accept all documents supporting Mr. Gay’s
financial situation, the Officer should have at least referred to the existence
of the property deed, bank statements and the letter of April 10, 2006, and,
stated the reasons for refusing to consider these documents in their entirety.
(Shaker
v. Canada (Minister of
Citizenship and Immigration), 2006 FC 185, [2006] F.C.J. No. 201 (QL).)
[30]
Justice
Michel Beaudry of the Federal Court states in Shaker, above, that when
the outcome of a decision is based on a particular piece of evidence, the
Officer should explain why a particular finding was made:
[38] I
agree with the applicant on this issue. In her assessment under the criteria of
the Act and Regulations, the Officer does not offer any explanation as to why
the applicant was awarded no points under the "Experience" and
"Arranged Employment" headings.
[39] Since
this failure to obtain any points under these headings played a considerable,
if not fatal part in the dismissal of the applicant's visa application, some
explanation for this finding would have been in order.
[40] Furthermore,
while test results may have been preferable to establish the applicant's level
of proficiency in English, the six manuscript pages submitted by the applicant
should have enabled the Officer to measure his proficiency against the
standards set out in the Canada Language Benchmark.
[31]
Therefore,
in ignoring Mr. Gay’s filed documentary evidence, the Officer erred in failing
to consider the totality of the evidence before her. (Ioda, above; Shaker,
above; Applicant’s Record, Affidavit of Herick Gay, Tab 3, para. 6.)
[32]
Justice
Dolores Hansen of the Federal Court has specified in Alimard v. Canada (Minister of
Citizenship and Immigration), [2000] F.C.J. No. 1223 (QL), that if an
Officer is not satisfied with the evidence submitted and that it is determined to
be incomplete, then, an opportunity must be given to the Applicant to provide
further evidence:
[15] In situations such as this, the jurisprudence is clear that
where a visa officer has an impression of deficiency in the proof being
offered, fairness requires that the visa officer give the applicant some
opportunity to disabuse the visa officer of that impression (Muliadi v.
Canada (Minister of Citizenship and Immigration) [1986] 2 F.C. 205).
[16] As the visa officer's finding that the applicant lacked
sufficient funds was a key factor in her assessment of his ability to
successfully establish a business in Canada, the applicant should have been given the opportunity to
address her concerns. He may have been able to provide her with evidence as to
the bona fides of the valuation or a new valuation.
[17] The respondent argued that it
was the failure of the applicant to submit valuations for all of his properties
which resulted in the visa officer being unable to make a proper assessment of
the applicant's financial ability. As was explained in Muliadi, supra,
this does not "relieve the visa officer of the duty to act fairly".
[33]
Justice
Eleanor R. Dawson of the Federal Court opined in Negriy v. Canada (Minister of
Citizenship and Immigration), [2000] F.C.J. No. 710 (QL), that a Visa
Officer’s obligation is to obtain further clarifications if doubt is expressed
in regard to the authenticity of evidence that has been provided:
[23] Once
information was received to the effect that the applicant's education was as
she had initially stated it to be, and once that information was accepted and
incorporated into the assessment, on receipt of a letter apparently under seal
from the Sanatorium Arcadia purporting to confirm the applicant's employment,
it was not in my view reasonable for the visa officer to reject the applicant's
application as she did.
[24] […]
further inquiries should have been directed as to the authenticity of the
letter under seal from the Sanatorium Arcadia before it was rejected.
[34]
Justice
Layden-Stevenson of the Federal Court determined in Zheng, above, at
paragraph 15, that a Visa Officer’s “failure to consider
[and include the Chinese properties in her calculation of the applicant’s
assets] constitutes [a] reviewable error. It is not a breach of procedural
fairness; it is a failure to consider evidence. If material to the result, the
decision must be set aside”.
[35]
In a
letter, dated May 25, 2006, which communicated the decision, refusing Mr. Gay’s
application for permanent residence to Canada, the Officer was silent on the
evidence that supported the Applicant’s claim (i.e.: the certified copy of a
property deed, showing the Applicant’s title to the land, a statement of the
Applicant’s net assets; and new bank statements which were received by the
Canadian Embassy on March 22, 2006). It is unclear whether the Officer even
considered the supporting evidence. Justice John Maxwell Evans of the Federal Court held in Cepeda-Gutierrez
v. Canada (Minister of
Citizenship and Immigration), [1998]
F.C.J. No. 1425 (QL):
[15] The Court may infer that the administrative agency under review made
the erroneous finding of fact "without regard to the evidence" from
the agency's failure to mention in its reasons some evidence before it that was
relevant to the finding, and pointed to a different conclusion from that
reached by the agency. Just as a court will only defer to an agency's
interpretation of its constituent statute if it provides reasons for its
conclusion, so a court will be reluctant to defer to an agency's factual
determinations in the absence of express findings, and an analysis of the
evidence that shows how the agency reached its result.
[16] On the other hand, the reasons given by administrative agencies are
not to be read hypercritically by a court (Medina v. Canada (Minister of Employment and Immigration)
(1990), 12 Imm. L.R. (2d) 33 (F.C.A.)), nor are agencies required to refer to
every piece of evidence that they received that is contrary to their finding,
and to explain how they dealt with it (see, for example, Hassan v. Canada
(Minister of Employment and Immigration) (1992), 147 N.R. 317 (F.C.A.).
That would be far too onerous a burden to impose upon administrative
decision-makers who may be struggling with a heavy case-load and inadequate
resources. A statement by the agency in its reasons for decision that, in
making its findings, it considered all the evidence before it, will often
suffice to assure the parties, and a reviewing court, that the agency directed
itself to the totality of the evidence when making its findings of fact.
[17] However, the more
important the evidence that is not mentioned specifically and analyzed in the
agency's reasons, the more willing a court may be to infer from the silence
that the agency made an erroneous finding of fact "without regard to the
evidence": Bains v. Canada (Minister of Employment and Immigration)
(1993), 63 F.T.R. 312 (F.C.T.D.). In other words, the agency's burden of
explanation increases with the relevance of the evidence in question to the
disputed facts. Thus, a blanket statement that the agency has considered all
the evidence will not suffice when the evidence omitted from any discussion in
the reasons appears squarely to contradict the agency's finding of fact.
Moreover, when the agency refers in some detail to evidence supporting its
finding, but is silent on evidence pointing to the opposite conclusion, it may
be easier to infer that the agency overlooked the contradictory evidence when
making its finding of fact.
[36]
Moreover,
Mr. Gay submits that the Officer failed to comply with the recommendations
stated in Section 8.2 of the OP6 Manual, which state that
the Officer “will advise the Applicant of the Officer’s specific settlement
funds concerns and give the Applicant the opportunity to address this problem”.
If the Applicant is unable to demonstrate sufficient available funds to meet
the requirements, “the officer will refuse the application” (Applicant’s Record,
Tab 7, Section 8.2 of the OP6 Manual); however, the Federal Court and the
Federal Court of Appeal have made it clear that guidelines and policy
statements like the OP6 Manual do not have the force of law and are not
enforceable by members of the public. (Ramoutar v. Canada
(Minister of Employment and Immigration), [1993] F.C.J. No. 547
(QL); Vidal v. Canada (Minister of Employment and Immigration), [1991]
F.C.J. No. 63 (QL).)
[37]
With regard to the weight given to the use of guidelines and
policy statements in order to determine if the Officer has made a reviewable
error, Justice Barry L. Strayer of the Federal Court notes in Vidal, above:
I would observe in passing that it must
follow as a corollary of the reasoning of Jerome A.C.J. in Yhap that an
applicant cannot complain if an immigration officer fails or refuses to follow
the Minister's guidelines. Nor can he complain if an immigration officer
applies any factor in lieu of those in the guidelines as long as this is done
in good faith and the factor is not wholly irrelevant to any conceivable view
of humanitarian and compassionate considerations. Further, it is for the
officer to decide if he is convinced of the truth of an applicant's assertions,
unless perhaps he makes findings of fact which are clearly without regard to
any material before him. It is not for the Court to sit in appeal on his
findings of fact or his weighing of the various factors.
…
I am satisfied that these guidelines
adequately convey to immigration officers that, particularly in respect of
humanitarian and compassionate considerations, the guidelines are not to be
regarded as exhaustive and definitive. It is emphasized and reemphasized that
officers are expected to use their best judgment. I believe they amount to
"general policy" or "rough rules of thumb" which Jerome
A.C.J. recognized as permissible in the Yhap case. I would go farther
than Jerome A.C.J. and say that such guidelines are not only permissible but
highly desirable in the circumstances.
[38]
The Respondent argued, however, that the Officer
acted fairly and consistently with the OP6 Manual in this case – because she
sent the Applicant a “fairness letter”, dated March 22, 2006, which informed
the Applicant that he would have to provide proof of the availability of his
settlement funds before his dossier could be finalized; therefore, the
Applicant was informed that the information he had provided in his application
with respect to his settlement funds was insufficient. (Applicant’s Record, p.
13, Tab 3, Exhibit B; Affidavit of Herick Gay, paras. 4-6.)
[39]
Nevertheless, the Officer should have informed Mr.
Gay of concern with regard to the documents provided in support of his
financial capacity to become economically established in Canada.
The Officer should, thus, have afforded him an opportunity to respond to
concerns relating to a material aspect of the application.
[40]
The Officer did not set out her findings of fact in respect
of the evidence upon which those findings were based. As the Officer did not
specify her reasons in that regard, the reasons failed to reflect on the main
relevant factors regarding Mr. Gay’s application for permanent residence. (VIA Rail
Canada Inc. v. Lemonde, [2000] F.C.J. No. 1685 (QL).)
[41]
Justice
Claire
L’Heureux-Dubé of the Supreme Court of Canada addressed the importance of
setting out reasons in Baker v. Canada
(Minister of Citizenship and Immigration),
[1999] 2 S.C.R. 817:
[39] Reasons, it has been
argued, foster better decision making by ensuring that issues and reasoning are
well articulated and, therefore, more carefully thought out. The process of
writing reasons for decision by itself may be a guarantee of a better decision.
Reasons also allow parties to see that the applicable issues have been
carefully considered, and are invaluable if a decision is to be appealed,
questioned, or considered on judicial review: R. A. Macdonald and D. Lametti,
"Reasons for Decision in Administrative Law" (1990), 3 C.J.A.L.P.
123, at p. 146; Williams v. Canada (Minister of Citizenship and Immigration),
[1997] 2 F.C. 646 (C.A.), at para. 38. Those affected may be more likely to
feel they were treated fairly and appropriately if reasons are given: de Smith,
Woolf, & Jowell, Judicial Review of Administrative Action (5th ed. 1995),
at pp. 459-60. I agree that these are significant benefits of written reasons.
[42]
Justice
J. Edgar Sexton of the Federal Court of Appeal noted in VIA Rail, above:
[22] The obligation to provide
adequate reasons is not satisfied by merely reciting the submissions and
evidence of the parties and stating a conclusion. Rather, the decision maker
must set out its findings of fact and the principal evidence upon which those
findings were based. The reasons must address the major points in issue. The
reasoning process followed by the decision maker must be set out and must
reflect consideration of the main relevant factors.
[43]
In
her letter, dated March 22, 2006, the Officer was silent on the evidence that
supported the Mr. Gay’s claim. Mr. Gay effectively met the required amount of
CDN $10,168.00 in financial resources for establishment in Canada. Her failure to mention
important pieces of evidence resulted in her having made an erroneous
finding of fact "without regard to the evidence" before her (i.e. the
certified copy of a property deed showing the Applicant’s title to the land, a
statement of the Applicant’s net assets and new bank statements).
[44]
Based on the foregoing, the application for judicial review is
granted and the Applicant’s file is referred for redetermination to another
Officer.
JUDGMENT
THIS COURT ORDERS that the application for judicial review be granted and the Applicant’s
file be referred for redetermination to another Officer.
“Michel M.J. Shore”
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