In the decision Cyanamid Canada Inc. v. Canada (Minister of National Health and Welfare) (1992), 45 C.P.R. (3d) 390, [1992] F.C.A. No. 950 (C.A.), the Court ruled that a government institution must be reasonably satisfied of the requester’s right of access and that there has to be some evidence.
The institution must have sufficient information to be satisfied that the requester meets the requirements of the Act. It must be in possession of sufficient indicators of presence in Canada at the time the request was made, residence in Canada or Canadian citizenship, or proof that the requester is a permanent resident within the meaning of the
Immigration and Refugee Protection Act.