Goel v. Canada (Citizenship and Immigration), 2025 FC 275 : Express Entry Reconsideration Refusal Set Aside After IRCC Failed to Address Evidence That the Submitted Document Was a Marriage Certificate

The Federal Court reviewed IRCC’s refusal to reopen Nitika Goel’s Express Entry PR application. IRCC had rejected the application as incomplete because it concluded that she submitted a marriage licence rather than a marriage certificate. In her reconsideration request, the applicant disputed that characterization and explained that the document was an expedited marriage certificate issued by Ontario’s Registrar General. The Court found the reconsideration decision unreasonable because IRCC repeated its original conclusion without addressing the applicant’s detailed explanation.

Key Principle

A decision rejecting an immigration application as incomplete remains subject to judicial review where the applicant disputes the finding of incompleteness. When reconsideration submissions directly challenge IRCC’s characterization of a document and provide a detailed explanation of why it satisfies the applicable requirement, IRCC must meaningfully engage with that central argument. Simply repeating the original conclusion does not provide the justification, transparency, or intelligibility required of a reasonable decision.

Background

The applicant submitted an Express Entry PR application that included a document relating to her marriage.

IRCC rejected the application as incomplete, concluding that she had provided a marriage license instead of the required marriage certificate.

The applicant requested reconsideration. Her representative explained that the document was an expedited marriage certificate, contained a certificate number and the Deputy Registrar General’s signature, and had been issued in that format because the ordinary certificate would take longer to produce.

IRCC refused to reopen the application, stating only that the submitted document was a marriage license.

Court Findings

• Matter Was Justiciable

The applicant did not admit that her application was incomplete or seek to correct a missing document. She directly challenged IRCC’s determination that the submitted document was insufficient.

• Earlier Incompleteness Cases Were Distinguishable

The cases relied on by the Minister involved applicants who acknowledged errors or missing materials and later attempted to submit corrected applications.

• Central Submission Was Ignored

IRCC did not address the applicant’s explanation that the document was an emergency or expedited marriage certificate.

• Repetition Was Not Reasoning

Merely stating again that the document was a marriage license did not demonstrate that IRCC considered the applicant’s supporting explanation.

• Court Could Not Decide the Document’s Status

The Court’s role was not to determine whether the document was legally a marriage certificate, but to assess whether IRCC reasonably addressed the reconsideration request.

Outcome

The Federal Court granted judicial review, set aside IRCC’s reconsideration refusal, and returned the matter for reconsideration. No question was certified.

Case Citation:

Goel v. Canada (Citizenship and Immigration), 2025 FC 275 (CanLII)