Golmohammadi v Canada (Citizenship and Immigration), 2026 FC 428: Failure to Engage with Study Plans and Family Ties Leads to Study Permit Refusal Being Unreasonable

Introduction

The Federal Court reviewed the refusal of study permit applications submitted by two minor applicants seeking to study in Canada, along with a temporary resident visa application submitted by their mother. The visa officer refused the study permit applications based on concerns regarding the applicants’ study plans and whether they had sufficient motivation to return to Iran after completing their studies. The mother’s temporary resident visa application was refused as a consequence of the refusal of her children’s applications. The Court granted judicial review, finding that the officer failed to meaningfully engage with the evidence and submissions provided regarding the applicants’ educational plans and family ties in Iran.

Key Principle

A visa officer must meaningfully consider the evidence and submissions provided by an applicant when assessing a study permit application. While officers are not required to address every piece of evidence, their reasons must demonstrate that they engaged with the central issues raised by the applicant.

Background

The minor applicants, citizens of Iran, applied for study permits after being accepted to study with the Toronto District School Board. Their mother applied for a temporary resident visa to accompany them to Canada and assist them with adjusting to life in Canada while they began their studies.

The applications were initially refused in January 2024 but were reopened for redetermination after judicial review proceedings were started. The applicants provided updated documents and further information before the applications were refused again in August 2024.

The officer refused the study permit applications on two grounds. First, the officer found that the applicants’ study plans did not sufficiently explain how their proposed Canadian education would benefit them at their current stage of life. Second, the officer found that the applicants did not have sufficiently strong family ties to Iran to motivate their return. The mother’s temporary resident visa application was refused because it was based on the refusal of her children’s study permit applications.

Court Findings

· Failure to Consider Detailed Study Plans

The Court found that the officer’s concerns about the applicants’ study plans did not correspond with the evidence submitted. The study plans contained detailed explanations regarding the benefits of Canadian education, including the quality of Canadian post-secondary education, the importance of studying in English, and the applicants’ future goals of pursuing careers in nursing and medicine.

The applicants also explained that entering the Canadian education system earlier would help them adapt culturally, improve their language skills, and prepare for future education. The Court held that the officer failed to engage with these submissions and instead relied on a general conclusion that the study plans lacked sufficient detail.

· Failure to Address Evidence of Family Ties

The Court also found that the officer failed to consider important evidence relating to the applicants’ family ties in Iran. The officer concluded that the applicants’ ties to Iran were weak because their immediate family members would accompany them to Canada. However, the officer failed to address evidence that the applicants’ father and brother would remain in Iran.

The officer also failed to consider that the mother’s stay in Canada was intended to be temporary and that she planned to return to her employment in Iran after assisting her children’s adjustment. This evidence directly contradicted the officer’s conclusion that the applicants lacked sufficient motivation to return.

· Decision Lacked Responsiveness Under Vavilov

The Court held that the refusal decisions were unreasonable because the officer did not meaningfully engage with the central evidence and submissions. The issue was not that the officer reached an unfavourable conclusion, but that the reasoning did not demonstrate consideration of the information provided by the applicants.

Outcome

The Federal Court granted the application for judicial review, set aside the refusals of the study permit and temporary resident visa applications, and returned the matters to a different officer for redetermination. No question was certified for appeal.

Case Citation:

Golmohammadi v. Canada (Citizenship and Immigration), 2026 FC 428 (CanLII)