Date: 20071210
Docket: IMM-4468-06
Citation: 2007 FC 1293
Ottawa, Ontario, December 10, 2007
PRESENT: The Honourable Mr. Justice Mandamin
BETWEEN:
RUPINDER
SINGH TATHGUR
Applicant
and
THE MINISTER OF CITIZENSHIP
AND
IMMIGRATION
Respondent
REASONS FOR JUDGMENT AND
JUDGMENT
[1] In 2001, Mr.
Rupinder Singh Tathgur (the “Applicant”) applied for a permanent resident visa
as a member of an economic - skilled worker class. The Immigration Officer,
Heather Dubé, (the “Visa Officer”) determined that the Applicant did not meet
the requirements for immigration to Canada as a permanent resident under an economic – skilled worker class. The
Applicant now seeks judicial review of the Visa Officer’s decision refusing the
Applicant’s application for a permanent resident visa.
Background
[2] The Applicant
is a citizen of India. He
has a Bachelor’s degree from Punjab Technical University in Jalander, India and was working as a
self-employed engineer doing property evaluations for banks and undertaking
small projects for individuals. He applied for a permanent resident visa under
the assisted relative category and under three skilled worker classes:
Contractor and Supervisor – Mechanics and Trades, Construction Estimator and
Civil Engineering Technologists and Technicians. The Visa Officer determined
he only qualified under the Civil Engineering Technologists and Technicians
category and assessed him on that basis.
[3] Since the
Applicant’s application was made prior to January 1, 2002 and no assessment had
occurred by December 1, 2003, the Applicant was assessed under two sets of
criteria as provided by the transitional provisions set out under subsection
361(4) of the Immigration and Refugee Protection Regulations,
S.O.R./2002-227 (“IRPA Regulations”): the first being the IRPA
Regulations pursuant to the Immigration and Refugee Protection Act,
S.C. 2001, c. 27 (the “IRPA”) and the second being the Immigration
Regulations, 1978, S.O.R./78-172 (“Immigration Regulations, 1978”),
pursuant to the former Immigration Act, R.S.C. 1985, c. I-2 (the “Former
Act”).
[4] The Applicant
was assisted by an immigration consultant who transmitted the Applicant’s
request to the Immigration Section of the Canadian High Commission in New Delhi on January 19, 2001. The immigration
consultant submitted that the Applicant was fluent in English and made a
provisional request that, should the Applicant score less than the required
assessment units, the Visa Officer exercise discretion, in the Applicant’s
favour, as provided under subsection 11(3) of the Immigration Regulations,
1978, as was applicable at the time of the Applicant’s application.
[5] On March 31,
2004 the Applicant provided his International English Language Testing System
(the “IELTS”) results in compliance with the IRPA Regulations. The
Applicant was advised on June 15, 2004 that he did not obtain sufficient points
under the IRPA Regulations and that he would be assessed under the Immigration
Regulations, 1978, for which an interview was required. On June 5,
2006, the Visa Officer interviewed the Applicant. The language of the interview
was in English and the Visa Officer administered English reading and writing
tests in the course of the interview.
[6] In the
Applicant’s assessment under the Former Act, the Visa Officer
assessed the Applicant as scoring 64 units pursuant to the Immigration
Regulations, 1978, 6 units below the minimum 70 units required. The
Visa Officer scored the Applicant as attaining 2 units for proficiency in
English.
[7] At the
conclusion of the interview the Visa Officer advised the Applicant that he did
not meet the minimum units required and that he did not qualify to immigrate to
Canada under the Immigration
Regulations, 1978. He was asked if he had further information that he
would like considered. The Applicant said he felt the decision was unjust and
stated that he had the necessary qualifications. The Visa Officer sent the
refusal letter dated June 13, 2006 to the Applicant via his immigration
consultant. Following the June 13, 2006 letter, the immigration consultant
wrote to the Visa Officer requesting reconsideration of the application
submitting that the Applicant should receive more credits for his technical
experience, and knowledge of English. The immigration consultant reiterated that
the Applicant also had a close relative in Canada.
Issues
[8] The Applicant
raises two issues:
1. Did
the Visa Officer err in awarding only two out of a possible nine units of
assessment under the knowledge of English factor of Schedule I of the Immigration
Regulations, 1978?
2. Did
the Visa Officer err in failing to exercise her discretion pursuant to
subsection 76(3) of the IRPA Regulations or subsection 11(3) of the Immigration
Regulations, 1978?
Standard of Review
[9] The
standard of review of decisions made by Visa Officers has been the subject of
much analysis. The Supreme Court of Canada has held that while considerable
deference should be accorded to immigration officers, the absence of a
privative clause, the contemplation of judicial review by the Federal Court,
and the individualized nature of the decision suggest the standard be
reasonableness simpliciter (Baker v. Canada (Minister of Citizenship
and Immigration), [1999] 2 S.C.R. 817). On the narrower question of the
standard of review of Visa Officer’s assessment of language proficiency, the
standard has been determined to also be reasonableness simpliciter (Al-Kassous
v. Canada (Minister of
Citizenship and Immigration), 2007 FC 541 at para. 22).
[10] The exercise
of discretion by a Visa Officer pursuant to section 76(3) of the IRPA
Regulations or section 11(3) of the Immigration Regulations, 1978
can manifest itself in at least two ways. First is where the Visa Officer is
under an obligation to consider exercising statutory discretion by reason of
express request (Nayyar v. Canada (Minister of Citizenship and Immigration),
[2007] F.C.J. No. 342 at para. 13). Second is where the Visa Officer ought to
consider whether to exercise discretion to issue a visa to an applicant given
the facts revealed in the application for permanent residence (Savvateev v.
Canada (Minister of Citizenship and Immigration), [1999] F.C.J. No. 922 at
para. 11). In either case, inaction on the part of a Visa Officer to consider
whether to exercise discretion would be subject to judicial review as it would
be the result of a failure to do an act he or she was lawfully required to do
as provided for by section 18.1(3) of the Federal Courts Act, R.S.C.
1985, c. F-7, as am. In addition, this Court held in Nayyar, above, at
para. 8, that where a Visa Officer fails to consider the exercise of positive
discretion when specifically requested to do so in an applicant’s application
for permanent residence, this would constitute a breach of procedural fairness
and would be reviewed on the correctness standard. However, if the Visa
Officer does exercise the subsection 11(3) statutory discretion, the standard
of review would be on the reasonableness standard, (Chen v. Canada (Minister
of Citizenship and Immigration), [1999] F.C.J. No. 528 at para. 25).
The
Language Assessment under the Immigration Regulations, 1978
[11] Subsection
8(1) of Schedule I of the Immigration Regulations, 1978,
provides:
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(1) For the first official language, whether English or
French, as stated
by the person, credits shall be awarded according to the
level of
proficiency in each of the following abilities, namely,
speaking, reading
and writing, as follows:
15
(a) for an ability to speak, read or write fluently,
three credits shall be
awarded for each ability;
(b) for an ability to speak, read or write well but not
fluently, two credits
shall be awarded for each ability;
(c) for an ability to speak, read or write with
difficulty, no credits shall be
awarded for that ability.
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(1) Pour la langue
que la personne indique comme sa première
langue officielle,
le français ou l'anglais, selon son niveau de compétence à
l'égard de chacune
des capacités suivantes : l'expression orale, la lecture
et l'écriture, des
cr édits sont attribués de la façon suivante :
a) la capacité de
parler, de lire ou d'écrire couramment, trois crédits sont
attribués pour
chaque capacité;
b) la capacité de
parler, de lire ou d'écrire correctement mais pas
couramment, deux
crédits sont attribués pour chaque capacité;
c) la capacité de parler,
de lire ou d'écrire difficilement, aucun cr édit n'est
attribué pour cette capacité.
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[12] The Visa
Officer awarded the Applicant two credits each for speaking and reading well
and zero credits for writing with difficulty. The Immigration Regulations,
1978, at subsection 8(3), specify that credits are converted into units
of assessment as follows:
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(3) Units of assessment shall be awarded on the basis of
the total number
of credits awarded under subsections (1) and (2) as
follows:
(a) for zero credits or one credit, zero units;
(b) for two to five credits, two units; and
(c) for six or more credits, one unit for each credit.
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(3) Des points
d'appréciation sont attribués sur la base du
nombre total de
crédits obtenus selon les paragraphes (1) et (2), d'après
le barème
suivant :
a) zéro ou un crédit, aucun point;
b) de deux à cinq
crédits, deux points;
c) six crédits ou plus, un point par crédit
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The Applicant had
obtained four credits which translated to two units of assessment for knowledge
of English.
[13] The Applicant
submits that the Visa Officer should have awarded more units for knowledge of
English. He argues the Visa Officer unreasonably gave zero credits for his
English writing abilities under the Immigration Regulations, 1978,
despite the IELTS results, which are a component of the assessment under the IRPA
Regulations, indicating the Applicant had a moderate proficiency in all
four abilities: listening, reading writing and speaking.
[14] The Applicant
was entitled to be assessed under the Immigration Regulations, 1978
and the IRPA Regulations. Section 361(4) of the IRPA
Regulations reads:
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Pending applications — skilled workers
(4) Beginning on December 1, 2003, a
foreign national who is an immigrant who made an application under the former
Regulations before January 1, 2002 for an immigrant visa as a person
described in subparagraph 9(1)(b)(i) or paragraph 10(1)(b) of those
Regulations, other than a self-employed person within the meaning of
subsection 2(1) of those Regulations, and whose application is still pending
on December 1, 2003 and who has not, before that day, been awarded units of
assessment under those Regulations must, in order to become a permanent
resident as a member of the federal skilled worker class,
(a) be awarded at least the minimum number of units of
assessment required by those Regulations for a person described in
subparagraph 9(1)(b)(i) or paragraph 10(1)(b) of those Regulations, other
than a self-employed person within the meaning of subsection 2(1) of those Regulations;
or
(b) meet the
requirements of subsection 75(2) and paragraph 76(1)(b) of these Regulations
and obtain a minimum of 67 points based on the factors set out in paragraph
76(1)(a) of these Regulations (emphasis added).
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Demandes pendantes — travailleurs qualifiés
(4) À compter du 1er
décembre 2003, l’étranger qui est un immigrant et qui, avant le 1er
janvier 2002, a présenté conformément à l’ancien règlement une demande de
visa d’immigrant à titre de personne visée au sous-alinéa 9(1)b)(i) ou à l’alinéa
10(1)b) de l’ancien règlement, autre qu’un travailleur autonome au sens du
paragraphe 2(1) de ce règlement, et dont la demande est pendante le 1er
décembre 2003 et qui n’a pas obtenu avant cette date de points d’appréciation
en vertu de l’ancien règlement doit, pour devenir résident permanent au titre
de la catégorie des travailleurs qualifiés (fédéral) :
a) soit obtenir au moins le nombre minimum de
points d’appréciation exigés par l’ancien règlement à l’égard d’une personne
visée au sous-alinéa 9(1)b) de l’ancien règlement, autre qu’un travailleur
autonome au sens du paragraphe 2(1) de ce règlement;
b) soit
satisfaire aux exigences du paragraphe 75(2) et de l’alinéa 76(1)b) du
présent règlement et obtenir un minimum de 67 points au regard des facteurs
visés à l’alinéa 76(1)a) de ce présent règlement (nous soulignons).
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[15] However, these two statutory assessments are conducted separately within the context of
their respective schemes given the wording of the transitional provision that
provides for concurrent dual assessments. The difference in the
two methods of assessment of language proficiency is that under the Immigration
Regulations, 1978, the Visa Officer applies a more subjective
standard, including the administration of an English comprehension test as well
as assessment of writing sample while under the IRPA Regulations the
Visa Officer follows an objective approach involving standardized English tests
administered and assessed by an independent third party.
[16] For the assessment under the Immigration
Regulations, 1978, the Visa Officer assessed the Applicant’s
proficiency in English in the course of an interview conducted in English at
the Applicant’s request. The Visa Officer was aware that the Applicant asserted
he had a moderate fluency in English. She administered a reading and writing
exercise to the Applicant. The Visa Officer’s notes indicate that she assessed
the Applicant’s English listening, speaking, reading and writing with reference
to Canadian Language Benchmarks. Given the foregoing, I cannot conclude that
the Visa Officer’s conclusion about the Applicant’s proficiency in English, as
assessed under the Immigration Regulations, 1978, and in
particular his writing, was unreasonable.
Subsection 11(3), Discretion
under the Immigration Regulations, 1978
[17] The immigration consultant who
initially transmitted the applicant’s application for a permanent resident visa
made the following request:
“Although not anticipated, if Mr. Rupinder Singh Tathgur
scores less than 65 units of assessment, it is respectfully submitted that such
would not reflect Mr. Rupinder Singh Tathgur’s prospects of becoming
successfully established in Canada. We therefore request that you exercise positive
discretion under s.11 (3)of the Immigration Regulations, 1978 if
Mr. Rupinder Singh Tathgur scores less than 65 units of assessment (emphasis in
original).
[18] The Visa Officer’s denial
letter dated June 13, 2006 does not make any reference to consideration of this
request. The Visa Officer’s notes and her subsequent affidavit also do not
disclose if she considered exercising her discretion.
[19] Subsequent to the receipt of
the refusal letter, the immigration consultant wrote to the Visa Officer
requesting reconsideration of Mr. Tathgur’s application on the grounds that
more points should have been awarded for technical experience and knowledge of
English. The immigration consultant submitted that, as the Applicant had
education, experience, and a close relative in Canada, he
was suitable to become economically established in Canada.
The immigration consultant did not expressly renew the request that the Visa
Officer exercise the statutory discretion provided by subsection 11(3) of the Immigration
Regulations, 1978. Neither the Applicant’s Record nor the Visa
Officer’s refusal letter discloses any reply to the request for
reconsideration.
[20] Since neither the Visa
Officer’s notes of the interview nor her letter of June 13, 2006 make any
mention of her considering the request she exercise the subsection 11(3)
discretion, I conclude that she did not turn her mind to whether to exercise
the statutory discretion.
[21] The Applicant claims that, in
effect, the Visa Officer’s failure to consider exercising the statutory
discretion either under subsection 11(3) of the Immigration Regulations,
1978 or the same discretion under subsection 76(3) of the IRPA
Regulations is an error of law.
[22] The Respondent, the Minister of
Citizenship and Immigration, argues that the Visa Officer did not have to
consider exercising her statutory discretion under subsection 11(3) of the Immigration
Regulations, 1978 or subsection 76(3) of the IRPA Regulations
for the following reasons:
1) the Applicant’s request for the
exercise of statutory discretion was merely a pro forma request made in
his letter of application;
2) the Applicant did not specify reasons
for believing he would be successfully established in Canada when
he was given the opportunity to provide additional information and he did not
invoke the discretion by setting out such factors;
3) the Applicant did not request the
same discretion under subsection 76(3) of the IRPA Regulations; and
4) the exercise of
discretion should only be decisive in cases that provide unusual facts or where
an applicant comes close to the required units of assessment.
[23] The initial request for the
exercise of discretion under subsection 11(3) was made provisionally by the
immigration consultant at the beginning of the application process. However,
the request was clearly expressed and was not a pro forma request in
that it was not a mere formality empty of significance. The request
contemplated the possibility that the Applicant may not succeed in the regular
immigration visa assessment process and was tendered to address that prospect.
[24] The Applicant did not renew the
request at the close of the final session with the Visa Officer when he was
given the opportunity to provide further information or make further
submissions. It is understandable that the Applicant, disappointed with the
outcome of the interview, might not think of repeating a request that the Visa
Officer consider exercising her statutory discretion. Further, the Applicant
did not waive any consideration of the statutory discretion requested in his
initial application. For a waiver of his prior request, it would have to be
clear that the Applicant turned his mind to that matter. Neither the
invitation by the Visa Officer or the Applicant’s response demonstrates the
Applicant was mindful of, and waived, his initial request to have the Visa
Officer consider exercising her statutory discretion. Further, it is to be
noted that the immigration consultant did make a request for reconsideration
subsequent to the June 13, 2006 rejection by the Visa Officer.
[25] The Respondent states the
Applicant did not make a request for consideration under subsection 76(3) of
the IRPA Regulations. However, subsection
361(4) of the IRPA Regulations contemplates a dual assessment process
for those applicants caught by the transition from the Former Act to the
IRPA. Implicit in this transitional provision is the availability of
statutory exercise of discretion under either process whether pursuant to
subsection 11(3) of the Immigration Regulations, 1978 or
subsection 76(3) of the IRPA Regulations. I would conclude that the
Applicant, having requested consideration under the statutory provision under
subsection 11(3) and having been assessed under both the Immigration
Regulations, 1978 and the IRPA Regulations, is entitled to
have his request considered under the statutory discretion provision under both
the Immigration Regulations, 1978 and the IRPA Regulations.
I would also note that the Applicant submitted his application on January 19,
2001 and the IRPA Regulations did not come into force until 2002. It
was not possible, at the time of his application, for the Applicant to also
request the exercise of discretion under the IRPA Regulations.
[26] Subsection 11(3) of
the Immigration Regulations, 1978 states:
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11(3)
(3) A visa officer may
( a) issue an immigrant visa to an immigrant who is not
awarded the number of units of assessment required by section 9 or 10 or who
does not meet the requirements of
subsection (1) or (2), or
( b) refuse to issue an immigrant visa to an immigrant who
is awarded the number of units of assessment required by section 9 or 10,
if, in his opinion, there are good reasons why the
number of units of assessment awarded do not reflect the chances of the
particular immigrant and his dependants of becoming successfully established
in Canada and those
reasons have been submitted in writing to, and approved by, a senior
immigration
Officer (emphasis added).
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11(3)
(3) L'agent des
visas peut
(a) délivrer un visa
d'immigrant à un immigrant qui n'obtient pas le nombre de points
d'appréciation requis par les articles 9 ou 10 ou qui ne satisfait pas aux
exigences des
paragraphes (1) ou
(2), ou
(b) refuser un visa
d'immigrant à un immigrant qui obtient le nombre de points d'appréciation
requis par les articles 9 ou 10,
s'il est d'avis
qu'il existe de bonnes raisons de croire que le nombre de points
d'appréciation obtenu ne reflète pas les chances de cet immigrant particulier
et des personnes à sa charge de réussir leur installation au Canada et que ces
raisons ont été soumises par écrit à un agent d'immigration supérieur et
ont
çu l'approbation de
ce dernier (nous soulignons).
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[27] The Respondent submits that the
subsection 11(3) discretion is only a factor where it will likely have an
impact on the outcome. The Respondent relies on Chen, above, at para.
23, where Justice Evans characterized the exercise of discretion as residual
stating:
Without trespassing on the discretion conferred upon visa
officers by subsection 11(3), I would have thought that the discretion in question
is residual in nature, and should be decisive only in cases that present
unusual facts, or where the applicant has come close to obtaining 70 units of
assessment.
[28] In Lam v. Canada
(Minister of Citizenship and Immigration), [1998] F.C.J. No. 1239
at para. 6, Justice Rothstein noted that if an applicant wished to have a Visa
Officer exercise discretion under subsection 11(3) the applicant would have to
indicate some good reasons why a unit of assessment determination did not
reflect the chances of successful establishment in Canada by
the applicant. Justice Rothstein went on to state that:
Where an applicant has reason to believe he or she may be
successfully established in Canada, irrespective of the units of assessment determination, he
or she should apply for determination under subsection 11(3) setting forth
relevant reasons.
[29] It is not for the Court to
speculate on what the outcome of a Visa Officer’s exercise of the discretion
would be under subsection 11(3). As Justice Gauthier stated in Yan v. Canada
(Minister of Citizenship and Immigration), [2003] F.C. J. No.
655 at para. 24:
Nevertheless, even if at this stage the chance of success
of such a request appears very slim, the Court cannot conclude that a visa
officer would necessarily refuse to exercise the discretion provided in
subsection 11(3) of the Regulations in favour of Yun Yan. The court would have
to speculate about the results of such an exercise. This would mean going
beyond the exception to the strict rule that a breach of procedural fairness
will normally void the decision. (See Mobile Oil Canada Ltd. V.
Canada-Newfoundland Offshore Petroleum Board [1994] 1 S.C.R. 202, at page 228;
Yassine v. Canada (Minister of Citizenship and Immigration) (1994), 172 N.R.
308 (F.C.A.)). Therefore, the decision must be set aside.
[30] The legislation
gives the discretion to immigration officers who are knowledgeable in
immigration matters and skilled in such evaluations as to what may be good
reasons to grant an immigration visa notwithstanding the results achieved under
the Former Act and its regulations. In the application for a
permanent resident visa filed on behalf of the Applicant, the Applicant’s
immigration consultant sets out, in some detail, the Applicant’s personal
background and an estimate of the units of assessment that the immigration
consultant thinks the Applicant warrants. Further, the immigration consultant
provides a rationale for the units of assessment that he assesses in respect of
the education and training factor, the work experience factor, the knowledge of
English factor and the personal suitability factor. Immediately preceding the
request for the exercise of positive discretion, the immigration consultant
concludes that the Applicant meets the requirements set out under the
Immigration Regulations, 1978. I am satisfied that the rationale provided by
the consultant is “good reason” for the consideration of the exercise of
discretion. Where a “good reason” is offered by an applicant, as is the case
in this application, the Court ought not to speculate on the merits of the
reasons.
[31] Subsection 76(3) and 76(4) of the IRPA
Regulation states:
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Circumstances for officer's substituted evaluation
(3) Whether or not the skilled worker has been awarded the minimum
number of required points referred to in subsection (2), an officer may
substitute for the criteria set out in paragraph (1)(a) their evaluation
of the likelihood of the ability of the skilled worker to become economically
established in Canada if the number of points awarded is not a sufficient
indicator of whether the skilled worker may become economically established
in Canada (emphasis added).
Concurrence
(4) An evaluation made under subsection (3) requires the
concurrence of a second officer.
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Substitution de l’appréciation de l’agent à la grille
(3) Si le nombre de points obtenu par un travailleur
qualifié — que celui-ci obtienne ou non le nombre minimum de points visé au
paragraphe (2) — ne reflète pas l’aptitude de ce travailleur qualifié à réussir
son établissement économique au Canada, l’agent peut substituer son
appréciation aux critères prévus à l’alinéa (1)a) (nous soulignons).
Confirmation
(4) Toute décision
de l’agent au titre du paragraphe (3) doit être confirmée par un autre agent.
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[32] The IRPA legislation
also gives immigration officers discretion to grant an immigration visa
notwithstanding a negative assessment under its regulations. Again, it is not
for this Court to speculate on what the outcome of a Visa Officer’s exercise of
the discretion would be under subsection 76(3) of the IRPA Regulations.
[33] I would also note that in
enacting the IRPA Regulations, Parliament has departed from the wording
contained in the Immigration Regulations, 1978 with respect to a
Visa Officer’s exercise of discretion. Under the Immigration Regulations,
1978, a Visa Officer had the discretion to issue an immigrant visa
notwithstanding that an applicant had not achieved the number of units of
assessment required, if, in the Visa Officer’s opinion, there were good reasons
why the number of units of assessment awarded did not reflect the chances of
the applicant becoming economically established in Canada. Under the IRPA
Regulations, a Visa Officer may substitute the evaluation criteria if the number
of points awarded is not a sufficient indicator of whether the applicant will
become economically established in Canada.
[34] As a result of the change of
wording between the Immigration Regulations, 1978 and the IRPA
Regulations, the cases relied on by the Respondent, particularly, Chen¸
above, and Lam, above, are not directly on point as they refer only to
subsection 11(3) of the Immigration Regulations, 1978 and the
Applicant in the case at bar was considered under both sets of regulations.
The Respondent argued that the Applicant, in requesting the exercise of
discretion, did not specify the reason for believing he would be successfully
established in Canada despite not meeting the assessment
requirements. While having already decided that the applicant did offer “good
reason” for the consideration of positive discretion, it is clear that the IRPA
Regulations impose no such requirement.
Conclusion
[35] In result, the Visa Officer was
asked by the Applicant’s agent to consider exercising the statutory discretion
under subsection 11(3) of the Immigration Regulations, 1978.
The Visa Officer did not consider exercising her discretion as requested. Nor
did the Visa Officer consider exercising her statutory discretion under
subsection 76(3) of the IRPA Regulations. The failure by the Visa
Officer to consider exercising the statutory discretion when requested to do so
is a failure carry out a statutory responsibility the Visa Officer was
obligated to do.
[36] The request for judicial review
is granted. The decision of the Visa Officer refusing the Applicant’s request
for a permanent immigration visa as a member of a skilled worker class is
quashed. The matter is to be referred to another Visa Officer for
consideration in a manner consistent with these reasons.
JUDGMENT
THIS COURT ORDERS AND
ADJUDGES that:
1. The application for judicial review is allowed.
The decision of the Visa Officer is quashed;
2. The matter is remitted to a different Visa
Officer for consideration;
3. No question is to be certified;
4. No order of costs.
“Leonard
S. Mandamin”
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