Ghajarzadeh v. Canada (Citizenship and Immigration), 2025 FC 1598 : Court Finds IRCC Unreasonably Rejected Study Plan Despite Promotion and Salary Increase Evidence

Introduction

The Federal Court reviewed IRCC’s refusal of Mahyar Ghajarzadeh’s study permit application. The applicant, an Iranian citizen, sought to complete a Project Management Graduate Certificate at Cambrian College. The officer refused the application after finding that the applicant had not demonstrated how the program would benefit him given his previous education and career. The Court granted judicial review, finding that the officer failed to meaningfully engage with evidence showing that the program was directly connected to a promotion and significant salary increase in Iran.

Key Principle

The Federal Court reaffirmed that study permit decisions must demonstrate a rational chain of analysis connecting the evidence to the conclusion. While visa officers are given discretion and are not required to provide lengthy reasons, they must address important evidence that contradicts their conclusions. Ignoring evidence of clear professional benefits may render a decision unreasonable under the Vavilov framework.

Background

The applicant, a 38-year-old citizen of Iran, held a Bachelor’s degree in Civil Engineering and a Master’s degree in Enterprise Entrepreneurship from Iranian universities. He applied for a study permit to complete a Project Management Graduate Certificate at Cambrian College.

In support of his application, the applicant submitted a study plan and supporting documents from his employer in Iran. The employer confirmed that completion of the Canadian program would allow the applicant to receive a promotion and a significant salary increase.

The applicant explained that the program was connected to his professional development and future employment opportunities. His study plan stated that he had received a job offer as a Project Manager from his current employer, conditional on completing the Canadian program. The offer included a projected salary increase of approximately 70% to 80%.

IRCC refused the study permit application. The officer concluded that the applicant had not demonstrated why the program would benefit him given his previous studies and current career. The officer acknowledged the employer letter but found that it did not sufficiently explain the necessity of international education.

 Court Findings

• Officer Failed to Consider Career Benefits

The Court found the officer’s reasoning unreasonable because it failed to address the central evidence supporting the study plan. The applicant had provided evidence of a promotion and substantial salary increase tied directly to completion of the Canadian program.

Justice Azmudeh held that it was difficult to understand how a professional promotion accompanied by increased wages could provide no benefit to the applicant.

• Reasons Were Arbitrary and Unsupported

The Court found that the officer referenced the employer letter but ignored important details within it. Simply mentioning evidence without analyzing its significance does not demonstrate meaningful engagement.

The Court emphasized that decision-making cannot rely on personal views or unsupported expectations. The phrase “to my satisfaction” cannot transform the assessment into a standard based solely on an officer’s personal opinion.

• Responsive Justification Required

Although officers have broad discretion, that discretion must be exercised based on evidence and objective reasoning. The officer was required to explain why the evidence of career advancement was insufficient, but failed to provide that analysis.

Outcome

The Federal Court granted the application for judicial review, set aside the study permit refusal, and remitted the matter to a different officer for redetermination. No question was certified.

Case Citation:

Ghajarzadeh v. Canada (Citizenship and Immigration), 2025 FC 1598 (CanLII)