Federal Court Upholds Study Permit Refusal

Date: 20260609 Docket: IMM-17270-24 Citation: 2026 FC 760 Toronto, Ontario, June 9, 2026 PRESENT: The Honourable Madam Justice Turley BETWEEN: [NAME] Applicant and THE MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent

REASONS AND

JUDGMENT [ 1 ] The Applicant, a citizen of Iran, sought a study permit to complete grade 12 in Canada at the same private high school in Ontario that he had attended virtually since September 2023. His app lication was refused because he did not establish that he would leave Canada at the end of his stay, as required by paragraph 216(1)(b) of the Immigration and Refugee Protection Regulations , SOR/2002-227 [ IRPR ]. [ 2 ] More particularly, a [NAME] officer determined that the purpose of the Applicant’s visit did not appear reasonable for two reasons. First, there were less expensive comparative courses offered in the Applicant’s home country. Second, the Applicant’s socio-economic situation was not sufficiently established to support a year of education in Canada. The Applicant seeks judicial review, arguing that the [NAME] officer’s decision fails to meet the requisite standard of reasonableness. [ 3 ] [ADDRESS] has recognized that [NAME] officers face a deluge of applications and that their reasons do not need to be lengthy or detailed to meet the threshold of reasonableness: [NAME] v Canada (Citizenship and Immigration) , 2025 FC 395 at para 7. However, an officer’s reasons “must be sufficient to allow the court to understand why the decision was made” : [NAME] v Canada (Citizenship and Immigration) , 2026 FC 97 at para 16. [ 4 ] In my view, considering the evidentiary record, the [NAME] officer’s reasons are sufficient to permit the Court to understand the basis for refusing the Applicant’s study permit: [COMPANY] v Canada , 2022 FCA 160 at para 10; [NAME] v Canada (Citizenship and Immigration) , 2025 FC 571 at para 19; [NAME] v Canada (Citizenship and Immigration) , 2024 FC 1476 at para 32. [ 5 ] The onus was on the Applicant to establish the merits of the educational program he sought to attend in Canada, with sufficient information justifying the course of study personally: [NAME] v Canada (Immigration Refugees and Citizenship) , 2024 FC 706 at para 12. Here, however, the Applicant’s stated reasons for completing high school in Canada were very general. For example, he stated that: “I am quite certain that the chosen high School will pave the way for honing personal and professional skills of mine, and make me capable of taking up better positions ahead in my home country.” [ 6 ] As the Respondent points out, the Applicant attended the same high school virtually for grades 10 and 11, and there was no justification offered as to why he could not similarly complete grade 12 by virtual attendance. In his study plan, the Applicant did not address the benefits of attending this school in person in terms of his future educational or employment pursuits. While Applicant’s counsel argued that completing high school in person in Canada would positively impact his pursuit of international studies, this was not evidence offered in the Applicant’s study plan. In the circumstances, I find that the [NAME] officer’s conclusion that the Applicant’s motivation to pursue studies in Canada did not seem reasonable is justified considering the evidentiary record. [ 7 ] I also find that the [NAME] officer’s conclusion that the Applicant’s family’s socio-economic situation was not sufficiently well established to support schooling in Canada is reasonable, based on the evidentiary record. To demonstrate sufficient funds, an applicant must establish that they have not only enough funds to pay tuition, but also their living and travel expenses: IRPR , s 220. [ 8 ] With respect to finances, in June 2024, the Applicant was asked to provide “evidence of funds which are completely available, transferable and unencumbered by debt or other obligations” and “[e]vidence of account activity showing 6 months of deposit & withdrawal history” . The Applicant submitted his mother’s banking information which showed an available balance of the equivalent of $85,005 Canadian as of July 2, 2024. However, the supporting bank statements reveal that the available funds in the mother’s bank account were limited, until an influx of deposits were made shortly after the Applicant was asked to provide evidence of available funds. [ 9 ] The Applicant addressed these transfers in a vague manner, simply stating that “some amounts were temporarily transferred to another account for a short-term investment that was planned but has now been canceled.” As this Court has held, an applicant must prove financial means with sufficient evidence: [NAME] v Canada (Citizenship and Immigration) , 2023 FC 1169 at para 12; [NAME] v Canada (Citizenship and Immigration) , 2022 FC 483 at para 19. Based on the limited evidence, the [NAME] officer’s conclusion about the insufficiency of funds is reasonable. [ 10 ] For these reasons, the application for judicial review is dismissed. The parties did not submit any questions for certification, and I agree that none arise.

JUDGMENT in IMM-17270-24 THIS COURT’S

JUDGMENT is that : The application for judicial review is dismissed. There is no question for certification. “Anne M. Turley” Judge FEDERAL COURT SOLICITORS OF RECORD DOCKET: IMM-17270-24 STYLE OF CAUSE: [NAME] v THE MINISTER OF CITIZENSHIP AND IMMIGRATION PLACE OF HEARING: BY VIDEOCONFERENCE DATE OF HEARING: JUNE 8, 2026

REASONS AND

JUDGMENT: TURLEY J. DATED: JUNE 9, 2026 APPEARANCES: [NAME] For The Applicant [NAME] For The Respondent SOLICITORS OF RECORD: [COMPANY] and Solicitors\ Toronto, Ontario For The Applicant Attorney General of Canada Toronto, Ontario For The Respondent