I agree, if the viewpoint is looking at that requirement in a way that is restrictive, which I think is one possible interpretation of that.
The other way of looking at it—and this is somewhat hinted at in the bill—is the idea that you may have a case that's on the fence, but the interests of justice pushes it over the fence in consideration of things like the distinct challenges of the applicant, the personal circumstances of the applicant. I actually think it can work both ways.
To the extent that you have a case that might be a wrongful conviction, but for some reason the public interest suggests it shouldn't be reviewed, I agree with you. That seems inconsistent with the spirit of the bill. That may be something that's left to the interpretation of the bill down the road, but it seems to me that interests of justice in no way could override the fact that there may be reasonable grounds to conclude that a miscarriage of justice occurred.