28 Commission has noted that, given the potential consequences the denial of protection may have for the 117 person concerned, "the interpretation of these exclusion clauses must be restrictive." 126. Finally, the Commission has underscored that while the right to asylum contained in Article 22(7) of the Convention implies no guarantee that refugee status will be granted, it necessarily 118 requires that the claimant be heard with due guarantees during the respective proceeding. In the following section, the Commission refers in greater detail to the link between this right and the right to a fair trial and judicial protection, as well as their specific implications. 2.2 The principle of non-return (non-refoulement) (Article 22(8) of the American Convention) 127. The principle of non-return (non-refoulement) is the keystone of the international protection of refugees and persons in similar circumstances. Article 33(1) of the 1951 Convention provides: No Contracting State shall expel or return ("refouler") a refugee in any manner whatsoever to the frontiers of territories where his life or freedom would be threatened on account of his race, religion, nationality, membership of a particular social group or political opinion. 128. Article 33(2) of the 1951 Convention stipulates that this benefit may not be claimed by a refugee whom there are reasonable grounds for regarding as a danger to the security of the country in which he is, or who, having been convicted by a final judgement of a particularly serious crime, constitutes a danger to the community of that country. 129. At the inter-American level the principle of non-return (non-refoulement) encloses an absolute protection, without exception, in articles 22(8) of the American Convention and 7(3) of the InterAmerican Convention to Prevent and Punish Torture, in the following terms: Article 22(8) of the American Convention In no case may an alien be deported or returned to a country, regardless of whether or not it is his country of origin, if in that country his right to life or personal freedom is in danger of being violated because of his race, nationality, religion, social status, or political opinions. Article 13 of the Inter-American Convention to Prevent and Punish Torture Extradition shall not be granted nor shall the person sought be returned when there are grounds to believe that his life is in danger, that he will be subjected to torture or to cruel, inhuman or degrading treatment, or that he will be tried by special or ad hoc courts in the requesting State. 130. Insofar as the instant case is concerned, the Commission has said that the obligation of non-return means that any person recognized or seeking recognition as a refugee can invoke this protection to prevent their removal. This necessarily requires that such persons cannot be rejected at the 119 border or expelled without an adequate, individualized examination of their claim. In addition to being expressly recognized in article 22(8) of the American Convention, the principle of non-return has been 117 IACHR, Report on the Situation of Human Rights of Asylum Seekers within the Canadian Refugee Determination System. OEA/Ser.L/V/II.106. Doc. 40. Rev. 1. February 28, 2000. par. 59. Cf. Office of the UNHCR, Handbook on Procedures and Criteria for Determining Refugee Status (reedited, Geneva, 1992) 118 IACHR - Canada. par. 60. Cf. in general, IACHR, Report No. 51/96. Decision of the Commission As to the Merits of Case 10.675. Interdiction of Haitian Boat People. United States. March 13, 1997. par. 163. 119 IACHR, Report on the Situation of Human Rights of Asylum Seekers within the Canadian Refugee Determination System. OEA/Ser.L/V/II.106. Doc. 40. Rev. 1. February 28, 2000. par. 25.