The issue arose in "Pham" because under Canadian federal law, a resident of Canada who is not a citizen can be removed from Canada if the person is convicted of certain types of criminal offences. The removal process is not part of the sentence for the criminal offence, and therefore is a collateral consequence. Once a non-resident person is required to leave Canada because of a criminal conviction, they are not entitled to come back to Canada unless they meet the rehabilitation requirements. A non-resident who is convicted of an offence carrying a life sentence is normally barred from Canada for life, if released from incarceration.