Odusanya v. Canada (Citizenship and Immigration), 2025 FC 1486 : Study Permit Refusal Maintained After Officer Found Large Deposits Unsupported by Evidence

The Federal Court reviewed IRCC’s refusal of Modupe Fausat Odusanya’s study permit application for a one-year Personal Support Worker Certificate program at St. Clair College. The applicant argued that she had demonstrated sufficient financial capacity through her employment, catering business, property ownership, and her husband’s financial support. The Court dismissed the judicial review, finding that the officer reasonably assessed the financial evidence and that the applicant failed to demonstrate clearly documented sources of funds.

Key Principle

The Federal Court reaffirmed that study permit applicants bear the responsibility of proving that they have sufficient and available financial resources to support their studies in Canada. Officers are entitled to examine the source, stability, and availability of funds. While decisions must be justified and transparent, the Court will not reweigh financial evidence where the officer’s assessment is reasonable. Applicants must organize financial records clearly and explain how funds were accumulated and obtained.

Background

The applicant, a citizen of Nigeria, applied for a study permit to attend St. Clair College with her two minor children. She provided evidence of financial capacity, including payment of CAD $10,000 toward tuition fees of approximately CAD $18,208, employment as a healthcare aide, ownership of a catering business, tax records, and property ownership.

The applicant’s financial documents included a Zenith Bank statement showing ₦10,216,921. She also provided evidence that her husband would support her studies. Her husband submitted financial records showing substantial bank balances, FIFA football agent credentials, brokerage agreements, agency contracts, and ownership interests in a sports agency.

The officer acknowledged that there appeared to be sufficient funds but found that the source of the funds was poorly documented. The officer was not satisfied that the applicant had provided sufficient evidence connecting the deposits and transfers to the claimed income sources.

Court Findings

• Source of Funds Assessment Was Reasonable

The Court found that the officer was entitled to examine whether the financial resources were properly supported. Although the applicant submitted extensive documentation, the officer reasonably found that the records did not clearly demonstrate how large deposits were accumulated or how they related to the claimed sources of income.

Justice Brown emphasized that applicants cannot simply provide large volumes of financial information and expect officers to independently identify relevant transactions. Applicants must assist decision-makers by explaining and organizing evidence.

• Court Cannot Reassess Financial Evidence

The Court rejected the applicant’s argument that the officer failed to properly weigh the financial documents. Judicial review does not allow the Court to substitute its own assessment for that of the officer unless there is a fundamental error.

Outcome

The Federal Court granted leave but dismissed the application for judicial review. The Court found that the officer’s refusal was reasonable and that no reviewable error occurred. No question was certified.

Case Citation:

Odusanya v. Canada (Citizenship and Immigration), 2025 FC 1486 (CanLII)