Federal Court: Unexplained Bank Deposits Are Fatal to Study Permit Applications
- Citation
- 2025 CF 1576
- Decided
- Court file
- IMM-10009-24
- Full judgment
- Read the decision
Case Law Overview
Kaji v. Canada (Citizenship and Immigration), 2025 CF 1576
A student from the Democratic Republic of Congo applied for a study permit to pursue an engineering degree. The visa officer refused the application due to insufficient financial resources, specifically citing limited evidence of sustained income and an unclear source of funds in her mother's bank account.
Court Ruling
The Federal Court dismissed the judicial review application, finding the officer's decision was reasonable. The Court affirmed that the onus is entirely on the applicant to provide clear, comprehensive proof of funds, and officers are not required to request more information if the evidence is lacking.
Key Quote from the Court
In particular, when a bank statement shows the deposit of large sums without the applicant having provided an explanation, it is reasonable to conclude that the source of the sums in question has not been demonstrated.
Expert Takeaways
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Explain Every Large Deposit Do not submit bank statements with recent, large, or unusual deposits without providing a detailed explanation and supporting documents (e.g., loan agreements, gift deeds, property sale documents). Officers will assume the worst if the source of funds is unclear.
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The Onus is 100% on the Applicant This case confirms a critical principle
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Transaction History Matters More Than the Final Balance Simply having the required amount in the bank on the day you apply is not enough. Officers conduct a detailed analysis of the account's history to verify a stable and legitimate source of funds. A consistent pattern of income is far more persuasive than a last-minute lump sum.
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New Evidence is Inadmissible at Court The court can only review the reasonableness of the officer's decision based on the exact information they had at the time. Any new explanations or documents you provide during the judicial review process will not be considered.
There is a deadline on this
That is the window to file an Application for Leave and for Judicial Review at the Federal Court, counted from the day you were notified of the decision. An extension can be requested, but it is granted at the Court's discretion - it is not automatic.
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That combination is worth a proper look. It does not mean you have a case - only a lawyer reading your actual documents can say that - but it does mean the question is worth asking before your filing window closes.
Disclaimer
The information provided in this article is for general informational purposes only and does not constitute legal advice. Immigration law is complex and subject to change. For advice specific to your situation, please schedule a consultation with a qualified legal professional.
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Questions people ask after reading a case like this
Does this mean my own case will succeed?
No. Every application is decided on its own record. A reported decision shows how the Federal Court has reasoned about a particular kind of error - it does not predict the result of a different file. What it can tell you is whether the problem in your refusal is the kind of problem the Court has been willing to intervene on.
How long do I have to challenge a refusal?
Under the Immigration and Refugee Protection Act you generally have 15 days to file an Application for Leave and for Judicial Review if the decision was made inside Canada, and 60 days if it was made outside Canada, counted from when you were notified. The Court can extend that period, but an extension is discretionary - it is not automatic.
What actually happens at the Federal Court?
Judicial review has two stages. You file the application and a written record, and a judge decides on paper whether to grant leave - permission for the case to proceed. If leave is granted, there is a hearing. The Court does not re-decide your immigration application; it decides whether the officer's decision was reasonable and procedurally fair. If you succeed, the file is normally sent back to be decided again by a different officer.
Do I have to be in Canada to bring an application?
No. Applicants outside Canada regularly bring judicial review applications, which is why the longer 60-day deadline exists for decisions made abroad. Applicants are not normally required to attend in person.
What happens in the free 15-minute review?
You explain what was refused or delayed and when you were notified. We tell you whether your filing window is still open, which issues in the decision look arguable, and what the realistic options are - including reapplying instead of litigating, where that is the better route. There is no obligation to retain us afterwards.
More Study Permit rulings
Federal Court: Vague Fairness Letter Invalidates Misrepresentation Finding
Court Backs Officer: Vague Study Plan and Unproven Funds Sink Study Permit
Federal Court: Security Checks Can Justify Study Permit Processing Delays
Court Rules Officers Can't Act as Career Counsellors in Study Permit Cases
Written by
Ali Dadkhah
Ali Dadkhah is a litigator whose practice is dedicated to challenging government decisions at the Federal Court of Canada. He specializes in judicial review, providing a crucial avenue for recourse for individuals and businesses who have faced unfair or unreasonable administrative outcomes. Bilingual legal support in English and Persian (Farsi)