Mohammad Abadi v. Canada (Citizenship and Immigration), 2025 FC 1637 : Study Permit Refusal Set Aside Where Officer Ignored Evidence Supporting Career Benefits

The Federal Court reviewed IRCC’s refusal of Sanaz Mohammad Abadi’s study permit application. The applicant, a citizen of Iran, sought to study English for Academic Purposes and the Post-Degree Marketing Management program at Langara College. The officer refused the application, finding that similar programs were available closer to home, that the applicant failed to demonstrate the benefit of studying in Canada, and that she lacked academic proficiency. The Court granted judicial review, finding that the officer failed to engage with key evidence supporting the applicant’s study plan.

Key Principle

The Federal Court reaffirmed that study permit decisions must demonstrate responsive justification under the Vavilov framework. While visa officers are not required to provide lengthy reasons, they must address the core evidence and submissions supporting an application. Officers must explain why important evidence does not overcome concerns regarding the purpose and benefit of studying in Canada.

Background

The applicant applied for a study permit to complete an English for Academic Purposes program and a Post-Degree Marketing Management program at Langara College. The officer refused the application on three main grounds:

• Similar programs were available closer to the applicant’s home at a lower cost.
• The applicant did not sufficiently explain why studying in Canada was necessary and beneficial.
• The applicant had not demonstrated the academic ability required to complete the program.

The applicant’s study plan explained that she wanted to improve her marketing, business management, and English skills because of a specific employment opportunity. She provided a letter from her employer explaining that the company planned to establish a new marketing and promotion department and that she was considered a suitable candidate to lead the department after completing the Canadian program.

The employer also confirmed that successful completion of the program would result in increased salary and commissions for the applicant.

➢ Court Findings

• Officer Failed to Consider Career Evidence

The Court found that the officer failed to engage with the strongest evidence supporting the study plan. The employer’s letter directly connected the proposed program to the applicant’s future career advancement, yet the officer’s reasons did not address this evidence.

Justice Pentney held that this was central to the applicant’s explanation for choosing the Canadian program and should have been considered.

• Cost Comparison Was Unsupported

The Court also found the officer’s conclusion regarding cheaper programs in the applicant’s home country unreasonable. The officer did not identify any specific alternative programs or provide objective evidence supporting the comparison.

The Court noted that officers may rely on their expertise, but important conclusions based on local knowledge must be reflected in the reasons.

• Academic Concerns Lacked Explanation

The officer questioned whether the applicant had sufficient academic proficiency but provided no explanation for this conclusion. The applicant had completed previous degrees with strong academic results and had received acceptance from Langara College.

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 reconsideration. No question was certified.

Case Citation:

Mohammad Abadi v. Canada (Citizenship and Immigration), 2025 FC 1637 (CanLII)