Federal Court Rejects Visa Refusal Judicial Review

Date: 20260121 Docket: IMM-814-25 Citation: 2026 FC 92 Toronto, Ontario, January 21, 2026 PRESENT: Mr. Justice Diner BETWEEN: [NAME] Applicant and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent

JUDGMENT AND

REASONS [ 1 ] The Applicant seeks judicial review of a decision of a visa officer [Officer] dated November 19, 2024 [Decision], refusing her application for a temporary resident visa [TRV]. For the reasons detailed here, I find the Officer’s Decision reasonable, and the application is dismissed. This matter was heard in a 45-minute oral hearing, under the Federal Court’s revised practice to hold shorter hearings for non-complex, temporary residence files, aimed to streamline procedures and promote consistency and efficiency in the litigation process. [ 2 ] The Applicant is a citizen of Iran. She applied for a TRV in order to visit her sister in Canada. The Applicant commenced a prior application for leave and judicial review. That matter was resolved by consent and the application was returned to [NAME] for redetermination. On redetermination, the application was assigned to a different officer. The Applicant was afforded an opportunity to submit updated information and documentation in support of her application. She did so. [ 3 ] Following review of the updated materials, the second officer [Officer] again refused the application, expressing concerns about the source and stability of the Applicant’s funds, the commensurability of the bank transactions with her stated income, and ultimately about whether the Applicant had satisfied the Officer that she would leave Canada at the end of the authorized period of stay. The burden rests on an applicant for a TRV to satisfy the officer that they will leave Canada by the end of the authorized period of stay. The Applicant now seeks judicial review of that Decision, claiming it to be unreasonable and unfair. [ 4 ] The presumptive standard of review applicable to the merits of the Decision is reasonableness ( Canada (Minister of Citizenship and Immigration) v [NAME] , 2019 SCC 65 at paras 15‑17 [ [NAME] ]). Allegations of procedural fairness are assessed by determining whether the process followed was fair in the circumstances ( [COMPANY] v Canada (Attorney General) , 2018 FCA 69, at para 54). [ 5 ] The Applicant has failed to convince me there was a reviewable error with the Officer’s analysis of the Applicant’s financial documents presented. The Applicant’s admitted failure to submit any new paystubs or declare additional income were open observations for the Officer to make. [ 6 ] It was the Applicant’s onus to ensure that all the dots of her application were connected, including with her finances, substantial evidence of which is required by the [NAME] (the post to which she submitted). Source of funds has been countenanced by this Court as a valid issue for officers to cite ( [NAME] v Canada (Citizenship and Immigration) , 2023 FC 1613, at para 29; [NAME] v Canada (Citizenship and Immigration) , 2025 FC 310, at para 19. [ 7 ] The onus also rested with the Applicant to provide updated documentation after her application was reopened at the [NAME]. It is trite law that applicants must put their best foot forward in TRV applications to visit family members in Canada, and when dealing with financial components of the application (see for instance [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1925 at para 8). This means that the Applicant cannot later fault the Officer before this Court for failing to make the appropriate connections within the morass of bank and personal financial documentation submitted to the Officer. [ 8 ] Indeed, the issue here was that multiple documents were presented without a proper explanation to guide the Officer, and without any clear path to match bank statements with source of funds, such as income. Guidance from the Applicant – or their representative of which there was none in this case – is particularly important in the current context where visa offices and officers are processing innumerable TRV applications. In a situation where there are many disparate numbers contained in multiple financial documents – such as was the case in this TRV application, including documentation submitted with the original, and then reopened application – the connections between the figures in various banking and payroll statements should either be clear on their face, or failing that, clearly explained by the applicant. Here, neither were done: there were no connectors provided for the Officer to make sense of the documents. Officers need this guidance to map out patterns in the constellation of documents and numbers presented. [ 9 ] As a result of the gap in the clarity of the documents – and attendant failure to provide any explanation to the [NAME] to make the connection between the payroll information and the banking information submitted – the financial component of the application lacked transparency. It was incumbent on the Applicant to provide an explanation for that component of the application, and in so doing elucidate the visa officer in being able to make the connections to establish the source of funds in the bank accounts. In the absence of clarity in documentation and/or an explanation from the Applicant, the Officer’s observations, and the resulting outcome, were reasonable. [ 10 ] Ultimately, the Applicant’s submissions before the Court amount to a disagreement with how the Officer weighed and assessed the evidence. It is not the role of the Court on judicial review to reweigh the evidence or to substitute its own assessment for that of the decision maker ( [NAME] v Canada (Citizenship and Immigration) , 2025 FC 1950 at para 4). [ 11 ] Finally, on procedural fairness, the Applicant was afforded an opportunity on redetermination to provide updated information. The Officer was entitled to assess the sufficiency of what was submitted. There is no general duty on visa officers to seek out additional evidence or to invite further explanations where the onus rests on the Applicant ( [NAME] v Canada (Citizenship and Immigration ), 2009 FC 336 at para 57). The process followed on redetermination was fair in all of the circumstances. [ 12 ] As the Applicant has not established that the Decision was unreasonable or unfair, the application for judicial review is dismissed.

JUDGMENT in IMM-814-25 THIS COURT’S

JUDGMENT is that : The application for judicial review is dismissed. No questions for certification were argued, and I agree none arise. There is no award as to costs. “Alan S. Diner” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-814-25 STYLE OF CAUSE: [NAME] v [NAME] OF HEARING:

HELD BY WAY OF VIDEOCONFERENCE DATE OF HEARING: january 14, 2026

JUDGMENT AND

REASONS: DINER J. DATED: january 21, 2026 APPEARANCES : [NAME] For The Applicant [NAME] For The Respondent SOLICITORS OF RECORD : [NAME] and Solicitors Toronto, Ontario For The Applicant Attorney General of Canada Toronto, Ontario For The Respondent