Docket: IMM-24472-24
Citation: 2026 FC 496
Toronto, Ontario, April 14, 2026
PRESENT: The Honourable Mr. Justice Ahmed
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BETWEEN:
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TEJINDER SINGH
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Applicant
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and
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THE MINISTER OF CITIZENSHIP AND IMMIGRATION
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Respondent
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JUDGMENT AND REASONS
(Delivered orally from the Bench in Toronto, Ontario, on April 14, 2026, and edited for grammar, syntax, and reference to jurisprudence)
[1] The Applicant seeks judicial review of a refusal of his work permit application pursuant to paragraph 200(1)(b) of the Immigration and Refugee Protection Regulations, SOR/2002-227.
[2] The Applicant is a citizen of India. In August 2024, the Applicant submitted a work permit application to be an agricultural worker in Manitoba.
[3] In December 2024, an officer of Immigration, Refugees and Citizenship Canada refused the Applicant’s work permit application. The officer was not satisfied that the Applicant would leave Canada at the end of his stay. Despite noting that the Applicant’s work contract was a fixed length, the officer determined that the Applicant had not shown any economic ties to India. In particular, the officer noted that the only proof of the Applicant’s Indian farm or restaurant businesses were photos of farm animals.
[4] The two issues before the Court are whether the officer’s decision is reasonable and procedurally fair.
[5] In my view, it is.
[6] The Applicant submits that the officer’s decision was made in a procedurally unfair manner because the officer should have sought clarification where the concerns were not evident on the record.
[7] I disagree. The Applicant had the onus of putting his best foot forward in his application (Rahman v Canada (Citizenship and Immigration), 2025 FC 1301 at para 11; Gupta v Canada (Citizenship and Immigration), 2019 FC 1270 at para 24). There is a low level of procedural fairness required for temporary resident visas and, accordingly, the officer did not have an obligation to notify the Applicant of missing documents in his application (Chiau v Canada (Minister of Citizenship and Immigration) (CA), 2000 CanLII 16793 (FCA)). Consequently, the Applicant’s submissions about a breach of procedural fairness cannot succeed.
[8] I also determine that the officer’s decision was reasonable in light of the applicable facts and law (Canada (Minister of Citizenship and Immigration) v Vavilov, 2019 SCC 65 at para 99). Contrary to the Applicant’s submissions, the officer explicitly considered the length of the Applicant’s work contract, his bank account statements, and his stated business activity in India to reasonably determine there was insufficient evidence on the record to establish viable economic ties or financial means within India.
[9] While I acknowledge that the officer did not address the Applicant’s family ties to India, including his wife and children who would remain in India, I do not consider this to be a fundamental flaw. It is well-established that the officer is presumed to have considered all of the evidence before them unless the evidence presents a direct contradiction to the officer’s findings (Khaleel v Canada (Citizenship and Immigration), 2022 FC 1385 at para 38; Khir v Canada (Citizenship and Immigration), 2021 FC 160 (“
Khir”
) at para 48).
[10] In this instance, the officer’s determination hinged on the Applicant’s businesses in India. Engagement with family ties is necessary where these factors are central to the temporary resident visa application. Failing to engage with this factor, in itself, is insufficient to warrant this Court’s intervention where it has no bearing on the officer’s determination or the Applicant’s submissions (Khir at para 48; Siddiqui v Canada (Citizenship and Immigration), 2025 FC 305 at paras 7-8; Kaur v Canada (Citizenship and Immigration), 2024 FC 1407 at para 14).
[11] I dismiss this application for judicial review.
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