Federal Court Rejects Study Permit Application Due to Insufficient Financial Evidence

Date: 20260710 [NAME] : IMM-5273-25 Citation: 2026 FC 930 Ottawa, Ontario , July 10, 2026 PRESENT: Madam Justice McDonald BETWEEN: [NAME] Applicant and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent

REASONS AND

JUDGMENT [ 1 ] [NAME], a citizen of Nigeria, seeks judicial review of the refusal of his study permit application. He was accepted into the aviation training program at Canadian Aviation College in British Columbia. The Officer refused the application because they were not satisfied that [NAME] had sufficient and available financial resources to fund his studies in Canada.

I. Issues [ 2 ] On this Application for judicial review, [NAME] argues that the decision is unreasonable and procedurally unfair.

II. Analysis A. Is the decision reasonable? [ 3 ] [NAME] argues that the Officer unreasonably found there was insufficient evidence explaining the source of his funds. He notes that he had paid 75% of the $107,575 tuition and had a $21,700 Guaranteed Investment Certificates [GIC] to cover living expenses. He also provided receipts from the sale of personal assets, a deed for land gifted to him, and bank statements that he says show contributions from family members. [ 4 ] The Officer’s assessment of the financial information is set out in the Global Case Management System notes, which form part of the decision. The Officer was concerned that the bank statements showed lump sum deposits without sufficient information on the source of the funds. The bank statements from July 2024 to January 2025 show lump sum deposits. Some identify the sender by name, while others identify only the sender’s account number or financial institution. [ 5 ] The only explanation in [NAME]’s study permit application regarding the source of these funds is the following, provided in his letter: The funds available in my bank account with [COMPANY] (CAD$27,835.79), is a collective support from family to see that I actualize my goal of becoming a commercial pilot is achieved. [ 6 ] This brief and general statement provides little clarity about the source of the funds. Some deposits, including most of the larger ones, do not identify the sender by name. Even where the sender is identified, there is no explanation or confirmation of who the sender is. None of the senders share [NAME]’s family name. It is therefore not apparent, on the face of the record, that these senders are related to him or why they provided him with funds. [ 7 ] Officers have a broad discretion when considering the source or nature of the funds relied upon to support an application. As noted in [NAME] v Canada (Citizenship and Immigration) , 2024 FC 2019 at para 13, citing [NAME] v Canada (Citizenship and Immigration) , 2023 FC 494 at para 12: …this Court has concluded in a number of recent decisions that a visa officer’s obligation to be satisfied as to the sufficiency and availability of funds goes beyond simply accepting financial documents at face value. In particular, visa officers must be satisfied as to the “source, nature, and stability” of funds, which is relevant to whether the funds shown in, for example, bank records will in fact be available to the applicant for the course of their studies [Citations omitted.]. As Justice Pamel, then of this Court, stated in [NAME] , “it is not a simple matter of reviewing the applicants’ bank account and, if they have sufficient funds, granting them a permit; the visa officer must conduct a more detailed and fulsome investigation about the source, nature, and stability of these funds”… [ 8 ] Here, the Officer was not satisfied that [NAME] had demonstrated the source, nature, and stability of the funds. Additionally, the Officer also found that [NAME] had not demonstrated sufficient resources to fund his studies in Canada. Although he identified other assets, the funds in his bank account formed a sizable portion of his available resources. In his study permit application letter, [NAME] described his available funds for living in Canada as follows: The funds available in my bank account with [COMPANY] (CAD$27,835.79), is a collective support from family to see that I actualize my goal of becoming a commercial pilot is achieved. Total sum available excluding tuition deposit and GIC is CAD$73,203.37-CAD$29,575(balance of tuition) =CAD$43,628.37(leftover for upkeep during my stay). [ 9 ] The funds in [NAME]’s bank account represented approximately 38% of his overall claimed funds. Given the Officer’s reasonable concerns about the source of those funds, and their significance to his ability to fund a two-year program in Canada, the Officer’s conclusion on this point was reasonable. [ 10 ] The fact that [NAME] says he was financially supported by family members did not require the Officer to accept that assertion without adequate supporting evidence. It remained open to the Officer to assess whether the record established the source, nature, and availability of the funds. [ 11 ] There was no further evidence or submissions before the Officer to substantiate these claims. The Officer cannot be faulted for failing to consider evidence that was not before them. In the circumstances, the Officer’s findings are reasonable. B. Procedural fairness [ 12 ] [NAME] argues that the Officer made a veiled credibility finding on the source of his funds and this should have triggered a procedural fairness obligation on the part of the Officer. He relies on [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1403 at para 9, which states: For example, where an officer suggests that the applicant’s supporting documents serve a “demonstrative purpose” amounting to a “deceptive façade”…or where, as here, the officer states that the applicant’s financial data has been “inflated” for purposes of advancing a visa application, a duty of fairness arises. The officer must give the applicant an opportunity to respond. There is a difference between finding that the source of the applicant’s funds is unclear (a question of the sufficiency of the evidence) and a conclusion that the applicant has misrepresented their financial means (an opinion about the applicant’s honesty). [ 13 ] [NAME]’s circumstances fall into the category where there was insufficient evidence regarding the source of the funds. As such, the Officer was under no obligation to provide [NAME] an opportunity to respond. No procedural fairness issues arise.

III. Conclusion [ 14 ] This judicial review is dismissed. There is no question for certification.

JUDGMENT IN IMM-5273-25 THIS COURT’S

JUDGMENT is that : The Application for judicial review is dismissed. There is no question for certification. No costs are awarded. blank "Ann Marie McDonald" blank Judge FEDERAL COURT SOLICITORS OF [NAME] : IMM-5273-25 STYLE OF CAUSE: [NAME] v mci HEARING

HELD BY VIDEOCONFERENCE AT : Ottawa, Ontario DATE OF HEARING: june 24, 2026

REASONS AND

JUDGMENT : McDonald J. DATED: July 10, 2026 APPEARANCES : [NAME] FOR THE APPLICANT [NAME] FOR THE RESPONDENT SOLICITORS OF RECORD : [NAME], Alberta FOR THE APPLICANT Attorney General of Canada Edmonton, Alberta FOR THE RESPONDENT