The Commission of Inquiry on War Criminals in Canada, often referred to as the Deschênes Commission, was established by the government of Canada in February 1985 to investigate claims that Canada had become a haven for Nazi war criminals. Headed by retired Quebec Superior Court judge Jules Deschênes, the commission delivered its report in December 1986 after almost two years of hearings. In 1985, Prime Minister Brian Mulroney ordered an investigation into the presence of Nazi war criminals in Canada after a member of Parliament claimed infamous Nazi doctor Joseph Mengele might be in the country. Mengele had indeed attempted to immigrate to Canada in 1962, and Canadian officials were aware of this at the time. The commission's final report was issued at the end of 1986 in two parts. The first part concluded that alleged Nazi war criminals had immigrated to Canada and in some cases were still residing in the country. The commission took a very broad approach to its mandate, investigating both allegations of war crimes (which were well-defined) and crimes against humanity (which at the time was a relatively new concept that concerned crimes that were not previously considered war crimes). The commission recommended changes to criminal and citizenship law to allow Canada to prosecute war criminals. In June 1987, the House of Commons passed legislation that allowed for the prosecution of foreign war crimes in Canadian courts and the deportation of naturalized war criminals. The second part of the final report, which concerned allegations against specific individuals, remains confidential and has never been made public. Canadian prosecutors pressed charges against at least four men on allegations of participation in Holocaust war crimes. One case ended in acquittal; two cases were dropped when prosecutors had trouble obtaining overseas evidence; the fourth case was stayed due to the health of the defendant. Since 1998, courts have found that six men misrepresented their wartime activities and could have their citizenship revoked although this was not done because the evidence was circumstantial and insufficient. Another seven people subject to deportation or citizenship-revocation procedures have died. Some individuals have criticized the commission for either exceeding its mandate or being overly influenced by foreign governments. Olga Bertelsen published an article undermining the claims made by the commission, and claiming that the Soviet KGB framed an innocent man, Ivan ("John") Demjanjuk, as part of a larger attempt (referred to as "Operation Payback")