The Minister of Immigration can certify that a person constitutes a threat or risk to security and, with Cabinet's approval, through an Order in Council, the Governor-General can order that that person be deported. There are limitations in relation to using this section to deport refugees. However, section 164 of the Act provides that, "A refugee or claimant for recognition as a refugee may be deported but only if Article 32.1 or 33 of the Refugee Convention allows the deportation of the person." So it is evident that the terrorist was considered a serious threat, given the surveillance he was placed under. So did he meet the criteria of article 32.1 of the refugee convention which states that, "The Contracting States shall not expel a refugee lawfully in their territory save on grounds of national security or public order"?