Federal Court Upholds Study Permit Refusal Decision

OUTCOME: Dismissed

Date: 20260522 [NAME] : IMM-13690-24 Citation: 2026 FC 661 Toronto, Ontario , May 22, 2026 PRESENT: Madam Justice McDonald BETWEEN: [APPELLANT] Applicant and MINISTER OF CITIZENSHIP AND IMMIGRATION Respondent

REASONS AND

JUDGMENT I. Background [ 1 ] The Applicant, a citizen of Iran, seeks judicial review of an Immigration Officer’s refusal of a study permit application. [ 2 ] The Applicant applied for a study permit to undertake a Master of Business Administration (MBA) at the [COMPANY] ([NAME]). Her acceptance was conditional and required her to complete pre-requisite courses at [NAME]. [ 3 ] In Iran, the Applicant is employed as a [NAME] at her father’s company. In her application, she included a letter from her employer stating that she would be promoted to [NAME] Director upon completion of an MBA program. [ 4 ] On July 15, 2024, the Officer rejected her application because they were not satisfied: (1) that she would leave Canada at the end of her authorized stay; and (2) that the purpose of her visit to Canada was not consistent with a temporary stay.

II. Issues [ 5 ] The Applicant claims the decision was unreasonable and was procedurally unfair. [ 6 ] Reasonableness requires a decision to have justification, transparency, and intelligibility, be based on an internally coherent and rational chain of analysis and be justified in relation to the facts and law that constrain the decision maker ( Canada (Minister of Citizenship and Immigration) v [NAME] , 2019 SCC 65 at paras 85-86). [ 7 ] Procedural fairness is evaluated on a correctness-like standard, where the Court asks “whether the procedure was fair having regard to all of the circumstances, including the [NAME] factors” ( [COMPANY] v Canada (Attorney General) , 2018 FCA 69 at para 54).

III. Analysis [ 8 ] The Applicant argues that the Officer’s decision is unreasonable on several grounds, including that the Officer improperly questioned the value of her further education. [ 9 ] The [NAME] ([NAME]) notes provide the Officer’s reasoning, and state as follows: … Study plan reviewed and considered. The applicant does not demonstrate to my satisfaction reasons for which such an educational program would be of benefit. In light of the [NAME]’s [Principal Applicant’s] previous study and current career, their motivation to pursue studies in Canada at this point does not seem reasonable. Applicant provided letter of support from their employer. Although the letter states a promotion it does not articulate in detail the necessity of the international education. [ 10 ] Although the Applicant submits that the Officer was obliged to provide more detail in analysing her application, this Court has repeatedly held that, given the high volume of applications and the need to process them quickly, [NAME] have only a limited duty to provide reasons for refusing a permit ( [NAME] v Canada (Citizenship and Immigration) , 2021 FC 596 at para 9). However, “[t]he reasons must permit this Court to understand why the decision was made and determine whether the conclusion falls within a range of possible, acceptable outcomes” ( [NAME] v Canada (Citizenship and Immigration) , 2019 FC 1146 at para 15). [ 11 ] Here the Officer considered the study permit and the employer letter, but was not satisfied that the information provided demonstrated the value of the proposed education. In the circumstances, the Officer’s reasons are sufficiently justifiable, transparent and intelligible. [ 12 ] The Officer was also concerned with the conditional acceptance letter. As noted by the Officer: I have concerns that [NAME] provided a conditional LOA. [NAME] will only be able to start MBA program upon successful completion of the Master of Business Administration Foundations with additional cost. [ 13 ] The Applicant’s acceptance letter indicated that she needed to undertake “Master of Business Administration Foundations” as preparatory study. The Officer expressed concerns that the Applicant needed to complete these pre-requisites to start her MBA program. [ 14 ] In her Application Record, the Applicant included a letter, dated “05/25/2024” , from the [COMPANY] in Tbilisi, Georgia, confirming that she was completing MBA foundational courses. This letter states that she would receive credit for these courses from [NAME], as part of a partnership between the [NAME] and the [COMPANY]. However, as noted by the Respondent, this letter appears to contain a discrepancy in the dates. Assuming the letter is dated May 25, 2024 – it notes start and finish dates that do not correlate with the date of the letter as follows: MBA Foundation Start Date: 05/06/2024 MBA Foundation Finish Date: 02/08/2024 [ 15 ] This letter is not in the Certified Tribunal Record and does not appear to have been before the Officer. The Applicant had until June 12, 2024, to submit additional supporting information, so it is unclear why the letter—if dated May 25, 2024—was not provided. In any event, even if the Officer had considered the letter, the date discrepancies make it unreliable. [ 16 ] In my view, the lack of evidence before the Officer addressing the conditions in the letter of acceptance is sufficient to uphold the reasonableness of the Officer’s decision. [ 17 ] On procedural fairness, the Applicant argues that the Officer made a negative credibility finding against her, in stating that she would not leave Canada at the end of her authorized stay. [ 18 ] This finding does not raise a procedural fairness issue, as the Officer is simply repeating the statutory language that applies to study permit applications, specifically subsection 216(1) of the Immigration and Refugee Protection Regulations , SOR/2002-227, which establishes the requirements for the issuance of a study permit, including that the “foreign national…will leave Canada by the end of the period authorized for their stay” . In any event, the Officer’s reasons in the [NAME] notes clearly focus on her study plan and its sufficiency, and do not address whether she would leave Canada. As such, this point is irrelevant to the Officer’s decision. [ 19 ] The Applicant has failed to demonstrate that the Officer’s decision was unreasonable or procedurally unfair. This judicial review is dismissed.

JUDGMENT IN IMM-13690-24 THIS COURT’S

JUDGMENT is that : This judicial review is dismissed. There is no question for certification. blank "Ann Marie McDonald" blank Judge FEDERAL COURT SOLICITORS OF [NAME] : IMM-13690-24 STYLE OF CAUSE: [APPELLANT] v mci HEARING

HELD BY VIDEOCONFERENCE AT : Toronto, Ontario DATE OF HEARING: april 22, 2026

REASONS AND

JUDGMENT : [NAME] J. DATED: May 22, 2026 APPEARANCES : [APPELLANT] [NAME] [APPELLANT] [NAME] FOR THE RESPONDENT SOLICITORS OF RECORD : [COMPANY], [NAME] of Canada Toronto, Ontario FOR THE RESPONDENT