Federal Court dismisses PRRA application judicial review

Date: 20260622 Docket: IMM-10814-25 Citation: 2026 FC 848 Ottawa, Ontario, June 22, 2026 PRESENT: The Honourable Mr. Justice Duchesne BETWEEN: [NAME] Applicant and THE MINISTER OF IMMIGRATION, REFUGEE AND CITIZENSHIP a/s MINISTRY OF JUSTICE Respondent

REASONS AND

JUDGMENT I. Overview [ 1 ] The Applicant is a failed refugee claimant from India who applied for a pre-approval risk assessment [PRRA] on November 13, 2024. The Immigration, Refugees and Citizenship [IRCC] officer assigned to consider and determine the Applicant’s PRRA application [the Officer] dismissed the application on March 3, 2025 [the Decision]. The Applicant seeks judicial review of the Decision. [ 2 ] The Decision reflects that the Officer accepted the Applicant’s evidence filed in support of his PRRA but nevertheless found that the Applicant had failed to establish that he faced a new risk as contemplated by sections 96 and 97 of the Immigration and Refugee Protection Act , SC 2001, c 27 [ IRPA ], if returned to India. The Officer found that the Applicant’s provision of financial support in the amount of $ 2,580.60 CAD to Indian farmer protests in India in March and April 2023, and the alleged police harassment of his father resulting therefrom, were not a sufficient basis upon which to grant his PRRA application. [ 3 ] Having considered the record before the court, as well as the arguments made by the parties during the hearing of this proceeding, I conclude that the Applicant has not established that the Decision is unreasonable or ought to be disturbed through the Court’s intervention. The Officer’s Decision is logical, coherent and intelligible in relation to the relevant factual and legal constraints. [ 4 ] The Applicant’s application is therefore dismissed for the reasons that follow.

II. Background [ 5 ] The Applicant is a citizen of India. He operated a flour mill next to his family’s farm in Village Kheri, Sangrur District, Punjab, India, prior to his arrival in Canada. His spouse and children remain in India. [ 6 ] The Applicant arrived in Canada on February 1, 2018, and made a refugee claim soon after his arrival. The Applicant’s refugee claim was based on his alleged risk upon his return to India as a result of him having reported criminal activity and denounced drug dealers in India. The Applicant had alleged, among other things, that he: a) was perceived as an activist and/or militant and faced risk at the hands of the police; b) feared the Indian police; and c) feared two drug dealers who operated in or near his village. [ 7 ] A panel of the Immigration and Refugee Board’s [IRB] Refugee Protection Division [[NAME]] heard the Applicant’s claim and found that he was neither a Convention refugee nor a person in need of protection pursuant to sections 96 and 97 of the IRPA . The determinative issue for the [NAME] was that the Applicant had an internal flight alternative [IFA] open to him in Mumbai. The [NAME] determined that the Applicant had fabricated key portions of his evidence and doubted the truthfulness of the Applicant’s testimony regarding some of the events that he alleged transpired in India while nevertheless finding some of the Applicant’s testimony otherwise credible. [ 8 ] The Applicant appealed the [NAME] decision to the Refugee Appeal Division [[NAME]] which dismissed his appeal. The [NAME] considered the Applicant’s evidence and arguments and found that he had not established that he was a person of interest for the police. In the end, the [NAME] agreed with the [NAME] that the Applicant had not established that the proposed IFA was unreasonable. [ 9 ] The Applicant sought judicial review of the [NAME] decision. The Federal Court did not grant leave to the Applicant and his application for judicial review was dismissed. [ 10 ] The Applicant submitted a PRRA application on November 13, 2024. The Applicant filed affidavit evidence that he had come to the attention of the police in India since his arrival in Canada because he sent the equivalent of $ 2,580.06 CAD through three electronic money transfers to his friend [NAME] in India to support farmer’s protests against farmer minimum wage and open market crop sale laws that detrimentally impact them and are perceived by the Applicant as being unfair. [ 11 ] The Applicant deposed that his trouble upon return to India would be compounded because he was already known by the police to be involved in activist causes. His evidence was that the police visited his father’s house in India on May 6, 2024, after they learned of the Applicant’s financial support of the farmer protests, during which the police communicated menacing intentions and threatened to harm the Applicant because they claimed that he worked against the government. The [NAME] suffered a heart attack at a later date and was hospitalized. The Applicant deposed that he is afraid for his father, his friends, his wife and his children, and suffers stress as a result. [ 12 ] In support of his PRRA application, the Applicant filed: a) additional affidavit evidence from: his father, his spouse, his friend [NAME], and his local Gurudwara president; b) medical evidence regarding his father’s heart attack; c) proof of his three money transfers; d) various news reports and articles regarding the farmer protests; and e) various reports regarding arbitrary detention and torture in India, none of which involve the Applicant, including: a report from the [NAME], and opinions from the [NAME]. [ 13 ] More importantly, the Applicant argued that the [NAME] and the [NAME]’s findings were not to be relied upon because “no real and reasonable IFA exists for someone in the applicant’s circumstances”.

III. The Decision [ 14 ] The Officer accepted the Applicant’s evidence that he provided financial support to his friend to help with the farmer protests in India. The Officer also accepted that the police in the Applicant’s village questioned the [NAME] multiple times in relation to the Applicant’s provided financial support, and that the [NAME] suffered a heart attack. The Officer further accepted that the police in India had been detaining peacefully protesting farmers who had, while in detention, faced mistreatment at the hands of the police. [ 15 ] The Officer considered the [NAME] and [NAME] decisions and gave them and their findings considerable weight regarding the risk faced by the Applicant upon his return to India. The Officer gave significant weight to the IFA available to the Applicant and to the [NAME] and [NAME] findings of fact that the police from his village would not have the capacity to track him the IFA location. After noting that a PRRA is neither an appeal nor a reconsideration of [NAME] or [NAME] decisions, the Officer held that there was insufficient evidence before them that an error was made, legal or otherwise, by the [NAME] or the [NAME] in the finding of an IFA for the Applicant. [ 16 ] The Officer found that the Applicant’s new evidence submitted with his PRRA application did not establish that the police in the Applicant’s village now had either the means or the ability to track the Applicant in Mumbai. [ 17 ] The Officer acknowledged the difficulties faced by those in the [NAME] in India but nevertheless determined that the Applicant had not led sufficient evidence that, aside from the local village police, the Applicant had come to the broader attention of [NAME] for activities either prior to or since his arrival in Canada. [ 18 ] The Officer determined that the Applicant had not provided evidence that demonstrated a material change that negated the [NAME]’s previously proposed IFA or established a new risk. The Officer consequently held that the Applicant had led insufficient evidence to establish that he would face a risk under section 96 or section 97 IRPA in India if returned and rejected the PRRA application.

IV. The Issue [ 19 ] The sole issue before the Court is whether the Decision is reasonable.

V. The Standard of Review [ 20 ] The parties agree that the applicable standard of review is the reasonableness standard of review. [ 21 ] The assessment of a risk upon return is a purely factual question and requires the application of the reasonableness standard of review. PRRA officers’ factual findings and assessment of the evidence are owed deference absent their being found unreasonable ( [NAME] v Canada (MCI), 2023 FC 570 at paras 11 and 12; [NAME] v Canada (MCI) , 2017 FC 1032 at para 15; [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1342 at para 3; [NAME] v Canada (Citizenship and Immigration), 2024 FC 202 at para 14; [NAME] v Canada (Citizenship and Immigration), 2020 FC 931 at para 8; [NAME]. c Canada (Citoyenneté et Immigration), 2025 CF 1838 at para 8). [ 22 ] The reasonableness standard of review was explained by the Supreme Court of Canada in Canada (Minister of Citizenship and Immigration) v [NAME] , 2019 SCC 65 [ [NAME] ]. The Supreme Court of Canada summarized the analytical approach set out in [NAME] in [NAME] v Canada (Citizenship and Immigration), 2023 SCC 21 at paras 7-8 as follows: [7] In [NAME] , this Court revised the framework for determining the standard of review. [ADDRESS] established a presumption that the standard of review of the merits of an administrative decision is reasonableness, subject to limited exceptions based on legislative intent or when required by the rule of law (paras. 10 and 17). The revised framework seeks to maintain the rule of law, while respecting a legislature’s intent to entrust certain decisions to administrative decision makers rather than courts (paras. 2 and 14). It also aims to bring simplicity, coherence, and predictability to the law on the standard of review and to eliminate the unwieldy exercise of determining the standard of review based on contextual factors, as had been required by this Court’s jurisprudence following [NAME] v. [NAME] , 2008 SCC 9, [2008] 1 S.C.R. 190 ( [NAME] , at paras. 7 and 10). [8] [NAME] also explained how a court should conduct reasonableness review. [ADDRESS] stressed that reasonableness review and correctness review are methodologically distinct (para. 12). Reasonableness review starts from a posture of judicial restraint and focusses on “the decision the administrative decision maker actually made, including the justification offered for it, and not on the conclusion the court itself would have reached in the administrative decision maker’s place” (paras. 15 and 24). When an administrative decision maker is required to provide reasons for its decision, reasonableness review requires a “sensitive and respectful, but robust” evaluation of the reasons provided (para. 12). A reviewing court must take a “reasons first” approach that evaluates the administrative decision maker’s justification for its decision (para. 84). An administrative decision will be reasonable if it “is based on an internally coherent and rational chain of analysis and is justified in relation to the facts and law that constrain the decision maker” (para. 85). [ADDRESS] also affirmed “the need to develop and strengthen a culture of justification in administrative decision making” (para. 2). [ 23 ] It is the Applicant’s onus to demonstrate that “any shortcomings or flaws are sufficiently central or significant to render the decision unreasonable” ( [NAME] at para 100). Absent exceptional circumstances, reviewing courts must not interfere with the decision-maker’s factual findings and cannot reweigh and reassess evidence considered by the decision-maker ( [NAME] at para 125; [NAME] v Canada ([NAME]), 2021 FCA 237 at paras 2 and 3).

VI. Arguments [ 24 ] The Applicant submits that the Decision is unreasonable due to errors of law and errors of factual assessment by the Officer. More particularly, the Applicant submits that: a) The Officer ignored objective country condition evidence contained in the National documentation package [NDP] and ignored other documentary evidence; b) The Officer erred by ignoring the cumulative profile of the Applicant; and c) The Officer ignored the arguments presented in the PRRA application. [ 25 ] Each of these arguments fail and must be rejected. A. The Officer considered the objective country condition evidence and documentary evidence [ 26 ] The Applicant argues that the Officer ignored most of the NDP extracts produced, other documentary evidence, and parts of the personal evidence. More precisely, the Applicant argues that the Officer failed to consider the affidavit evidence led, the documentary medical evidence filed regarding the [NAME], the money transfer receipts, produced protest photographs, and the [NAME] evidence filed. [ 27 ] The Officer explicitly identifies and refers to these documents in the Decision as having been considered. The Decision reflects that the Officer explicitly considered the money transfer receipts, the family member affidavits as well as the [NAME]’s affidavit, the medical reports produced, the police visits, the [NAME]’s heart attack and the photographs of the farmer protests. The Decision reflects that the Officer read and considered the submitted country condition documentation, including and specifically referring to CNN reports, the February 22, 2024, Amnesty International report submitted for the Officer’s consideration, and the submitted [NAME] documentation and Federal Court decisions. [ 28 ] The Applicant’s argument is ill founded in fact and must be rejected. [ 29 ] The Applicant’s argument suggests that the Officer was required to set out every fact, every document, and every argument advanced along with a detailed explanation for their assessment and determination of each. A PRRA officer’s decision and reasons are not required to go into such minute detail. There need not be an encyclopedic description of every piece of evidence, or of every argument made by each party ( [NAME] v Canada , 2016 FCA 180 at para 10). What is required is a rational chain of analysis that allows the court to trace the decision maker’s reasoning without encountering any fatal flaws in its overarching logic. There must be a line of analysis within the reasons that could reasonably lead the decision maker from the evidence before it to the conclusion at which they arrived ( [NAME] at para 102 and 128). The logical connection between “what” was decided and “why” it was decided must be apparent ( R. v R.E.M , 2008 SCC 51 at para 17; Canada ([NAME]) v B.W., 2025 FCA 199 at paras 20 to 23; [NAME] at para 128). The Officer’s reasons and the Decision meet that threshold. [ 30 ] The Applicant argues that the Officer ignored documentary evidence from NDP tabs 2.23 and 14.2, neither of which were produced either before the Officer or in the record before this Court. The Applicant argues that these two objective country condition documents ought to have been considered explicitly by the Officer because they reflect the repercussions suffered by people supporting the farmer’s protest and how a failed refugee Sikh like the Applicant, if deported, could face allegations of being an antinationalist, be interrogated for a longer time and have his luggage filled with false things like bullets, eventually leading to unlawful arrest and detention. In short, the Applicant argued that the Officer fell afoul the teachings in [NAME] v Canada (Minister of Citizenship and Immigration), 1998 CanLII 8667 (FC). [ 31 ] [ADDRESS] cannot agree. The jurisprudence is clear that an applicant must establish a link between the [NAME] documentary evidence, their specific circumstances and how they apply to them personally ( [NAME] v Canada (Public Safety and Emergency Preparedness) , 2025 CanLII 111025; [NAME] v Canada (Citizenship and Immigration), 2009 FC 266 at para 35; [NAME] v Canada (Citizenship and Immigration), 2024 FC 1828 at para 21; [NAME] v Canada (Citizenship and Immigration) , 2023 FC 195 at para 22; [NAME] v Canada (Citizenship and Immigration), 2016 FC 426 at para 19; [NAME] v Canada (Citizenship and Immigration), 2012 FC 1435 at para 26). That was not done here. [ 32 ] The Applicants’ first argument does not establish that the Decision is unreasonable. B. The Officer did not ignore the cumulative and intersectional profile of the Applicant [ 33 ] The [NAME] found that the Applicant did not have a forward-looking risk from the police in India. The evidence led as to the Applicant’s past profile in India led the [NAME] to find that the local police in the Applicant’s village did not truly believe that he was affiliated with gangsters or ex-militants or had any relations with militants. The [NAME] found that the Applicant was a regrettable victim of corrupt police practices in India. These findings were not disturbed by the [NAME] on appeal. [ 34 ] The [NAME] found that the Applicant had not established on a balance of probabilities that he was found in the police diary, would form part of the daily entries or be captured in the CCTNS database because he was neither a criminal nor a person of interest. [ 35 ] The Applicant therefore was not found to have the profile that he suggested he did, or that he had a forward-looking risk in India because of his profile. [ 36 ] The Officer accepted the Applicant’s evidence that he made financial contributions to the farmers protest. The Officer also noted that there was insufficient evidence to indicate that law enforcement authorities outside of the Applicant’s village were newly aware of, or had an interest in, the Applicant or his activities. Having made that finding, the Officer was unable to reach a conclusion different than the one made by the [NAME] or the [NAME] with respect to the Applicant’s forward-looking risk in India in the IFA. [ 37 ] The Officer found that the Applicant did not have a profile that would cause him to have a forward-looking risk in India prior to coming to Canada, and that his financial contributions to the farmers’ protest in the spring of 2023 did not enhance his profile in such as a way as to expose him to risk upon his return to India in the identified IFA location. [ 38 ] The Applicant argues that the Chairperson’s Guideline 8: Accessibility to IRB Proceedings — Procedural Accommodations and Substantive Considerations required the [NAME] to consider the intersectionality of the separate risks presented by the Applicant’s claim and to focus on the Applicant’s lived experiences. These Guidelines are not binding on the Court and, more importantly, there is no evidence that this Guideline and its content, or the cases relied upon by the Applicant, were raised or argued before the [NAME]. [ 39 ] The Applicant’s intersectionality argument is a new argument in that the Officer was not provided with the opportunity to consider it in the context of the PRRA application. [ADDRESS] cannot find the Officer’s Decision unreasonable for having not considered an argument that was not made before them ( [NAME] v Canada (Citizenship and Immigration), 2023 FC 875 at para 59). The Applicant’s intersectionality argument would fail and be of no assistance in any event. [ 40 ] The Applicant relies on Madam Justice Pallotta’s decision in [NAME] v Canada (Citizenship and Immigration), 2022 FC 41 [ [NAME] ], at paragraphs 12 and 13, in support of his intersectionality argument. The matter in that case involved a PRRA application by an applicant who suffered from mental illness and was suicidal and schizophrenic. A cumulative and intersectional risk assessment was warranted in those circumstances due to the applicant’s status as a returnee with severe mental illness, and as a returnee who would be suspected of serious criminality. The PRRA officer in [NAME] had failed consider the applicant’s profile cumulatively and evaluated the applicant’s two very different risks separately, while failing to engage with the evidence in the record. [NAME] does not assist the Applicant here because it is factually distinguishable. The Officer in this case assessed both strands of the Applicant’s alleged profile risk and explained why the Applicant had not made out his case. [ 41 ] The Applicant also relies on Madam Justice Azmudeh’s decision in [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1123 [ [NAME] ] in support of his argument. This decision is of no support to the Applicant either as it is factually distinguishable. The Officer here assessed both strands of the Applicant’s alleged risk and explained why the Applicant had not made out his case, while the PRRA officer in [NAME], failed to assess whether an aspect of an applicant’s profile could impact the other in a cumulative assessment in the larger context of a discussion regarding whether a serious issue for a stay had been made out. [ 42 ] The Officer’s reasoning and conclusions are supported by the evidentiary record and are logical and rational. The Applicant’s second argument does not establish that the Decision is unreasonable. C. The Officer did not ignore arguments made in the PRRA submissions [ 43 ] The Applicant argues that the Decision is silent without reason on important arguments based on decisions of this court and of the [NAME] that have parallels with the Applicant’s case. [ 44 ] The Officer explicitly acknowledges in the Decision that they read the [NAME] decisions and the Federal Court decisions the Applicant submitted. The Officer also explicitly acknowledged that the decisions submitted for consideration made different IFA findings than the [NAME] and the [NAME] had in this case but were not determinative. The Officer quite correctly explained their reasoning as follows: “However, while I acknowledge the adverse IFA findings from the provided documents and decisions, I note that each case is decided upon the merits of the evidence before the decision maker, and each case is inherently different. I note that in the case of the applicant, the [NAME] decision was appealed to the [NAME]. The applicant then sought leave to the FCC, which denied the leave, upholding the [NAME] decision. As such, the assessment of the IFA finding for the applicant was given full legal consideration and continues to stand. There is insufficient evidence before me that an error was made, legal or otherwise, in the finding of an IFA for the applicant. […]” [ 45 ] I am satisfied that the Officer’s reasoning reflects that they engaged with the arguments and the authorities relied upon by the Applicant and distinguished them based on the evidence before them as it applied to the Applicant. [ 46 ] The Applicant’s third and last argument does not establish that the Decision is unreasonable.

VII. Conclusion [ 47 ] The Applicant has not established that the Decision is unreasonable or ought to be disturbed by the Court’s intervention. I find that the Officer’s Decision is logical, coherent and intelligible in relation to the relevant factual and legal constraints that act upon them. The Applicant’s application is therefore dismissed. [ 48 ] Neither party has suggested that a serious question of [NAME] importance is involved in this proceeding and should be certified. I agree with the parties that none arises.

JUDGMENT in IMM-10814-25 THIS COURT’S

JUDGMENT is that : The Applicant’s application for judicial review is dismissed. There is no serious question of [NAME] importance involved in this proceeding to be certified. There are no costs awarded to either party. “Benoit M. Duchesne” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-10814-25 STYLE OF CAUSE: THE MINISTER OF IMMIGRATION, REFUGEE AND CITIZENSHIP a/s MINISTRY OF JUSTICE PLACE OF HEARING: montreal, quebec DATE OF HEARING: march 26, 2026

REASONS aND

JUDGMENT: duchesne, j. DATED: june 22, 2026 APPEARANCES : [NAME] For The Applicant [NAME] For The Respondent SOLICITORS OF RECORD : [COMPANY], Québec For The Applicant [NAME] of Canada Montréal, Québec For The Respondent