( iii) any available defence; and
( iv) the strength of connection between the plea of guilty and the
collateral consequence (where the collateral consequence
depends on the length of the sentence, a court may have
reason to doubt the veracity of the claim).
See Wong, at paras. 26, 28.
The principles applied
 As I will explain, I would not give effect to this ground of
appeal. In my view, the appellant has failed in his attempt to set
aside his guilty plea on the basis that it was uninformed because
he was unaware of the immigration consequences of his plea
and the sentence jointly proposed by counsel.
 At the outset, I do not contest the proposition that the
immigration consequences of an accused’s plea, conviction
and sentence fall within the legally relevant collateral consequences of which an accused must be aware to make an informed
 Two inquiries determine whether a guilty plea should be
set aside on the ground that it was uninformed because the
accused was unaware of legally relevant collateral consequences:
( i) Was the accused misinformed or not informed about a legally
relevant collateral consequence of entry of the plea?
( ii) Did this misinformation or lack of information result in prejudice to the accused?
 At the first step or stage of the analysis to determine
whether the accused was misinformed or not informed about
a legally relevant collateral consequence of his plea, the assessment is objective. In this case, the critical issue is whether the
accused was aware of the immigration consequences of his plea
to the extent necessary to meet the “informed” requirement for
a valid guilty plea.
 The authorities teach that where immigration consequences may ensue from a guilty plea, conviction and sentence,
an accused must be aware of those consequences for his or her
plea to be informed. Those immigration consequences include
removal from Canada — in a word, deportation. But the authorities have resisted imposition of a fixed quantum or standard of
information necessary to characterize the plea as “informed”.
Instead, the jurisprudence counsels a case-by-case analysis consistent with both the subjective nature of guilty pleas and the