Qaffari v. Canada (Citizenship and Immigration), 2026 FC 228 : Study Permit Refusal Set Aside After IRCC Ignored Material Evidence Supporting the Applicant’s Purpose of Studies and Career Advancement

The Federal Court reviewed the refusal of a study permit application submitted by an Iranian applicant who sought to pursue a Master of Finance at McMaster University. The visa officer refused the application after finding that the applicant had not demonstrated how the international educational program would benefit her and was not satisfied that she would leave Canada at the end of her authorized stay. The Court granted judicial review, finding that the officer failed to engage with the applicant’s detailed explanation of the program’s career benefits and improperly ignored significant evidence supporting her educational objectives.

Key Principle

While visa officers may assess whether a proposed Canadian educational program provides meaningful benefits to an applicant, they must genuinely engage with the applicant’s evidence and explanations. A study permit refusal is unreasonable where an officer overlooks material evidence supporting the educational purpose of the proposed studies or where government counsel attempts to supplement deficient reasons with new justifications during judicial review.

Background

The principal applicant, a citizen of Iran, held an associate degree in Accounting and Finance, a bachelor’s degree in professional auditing, and had been employed as the Head of Accounting for an Iranian company since 2021. She was admitted to the Master of Finance program at McMaster University, and her employer provided a letter confirming that she would be promoted to Financial Manager upon successfully completing the program.

In support of her study permit application, the applicant submitted a detailed Statement of Purpose explaining why the Canadian master’s program would strengthen her professional expertise and advance her long-term career in Iran. Her husband simultaneously applied for an accompanying open work permit.

The visa officer refused both applications, concluding that the applicant had not demonstrated that the international educational program would benefit her and was not satisfied she would leave Canada at the end of her authorized stay.

Court Findings

·         Officer Failed to Consider the Applicant’s Career Advancement Evidence

Justice Go held that although officers may assess whether a proposed educational program provides meaningful benefits, they must meaningfully engage with the evidence before them. The officer entirely failed to address the applicant’s detailed Statement of Purpose or the employer’s promotion letter demonstrating that completion of the Master’s program would directly advance her career upon returning to Iran.

·         Material Evidence Cannot Be Ignored

The Court found that the officer overlooked significant evidence pointing toward the opposite conclusion without offering any explanation. By failing to address the applicant’s educational rationale and documented career progression, the decision lacked the justification and transparency required under Vavilov.

·         Government Counsel Cannot Repair Deficient Reasons

During the judicial review, the Minister argued that the program was expensive relative to the applicants’ savings and that the promotion evidence was insufficiently detailed. The Court rejected these submissions because none of these reasons appeared in the officer’s GCMS notes. Judicial review must assess the reasons actually given by the decision-maker, not post hoc explanations advanced during litigation.

Outcome

The Federal Court granted the application for judicial review, set aside the study permit and accompanying work permit refusals, and returned the matter to a different visa officer for reconsideration. The decision reinforces that officers must meaningfully assess an applicant’s explanation of how a Canadian educational program advances their career objectives before concluding that the purpose of study is unreasonable.

Case Citation:

Qaffari v. Canada (Citizenship and Immigration), 2026 FC 228 (CanLII)