Explore the latest ImmPulse Weekly for key Canadian immigration insights—or browse past editions to catch up.
Immigration Minister Lena Diab says she wants Immigration, Refugees and Citizenship Canada to develop a clearer, system-level way to track how many temporary residents (including workers and students) actually leave Canada when their status expires, noting that while IRCC and the Canada Border Services Agency can track some information, there is currently “no simple way” to measure exits at scale; CBSA has told a parliamentary committee it can track who leaves (and basic travel data) but cannot determine whether someone is departing because a visa has expired without a labour-intensive, case-by-case review. The article situates this in the context of high volumes of expiring temporary permits (almost 1.9 million in 2026; more than 2.1 million in 2025) and increased asylum claims by some temporary residents in 2024, and notes Diab’s view that the government’s border security bill (C-12) and broader modernization efforts, including pilots for online passport renewals and digital visas, are part of restoring public confidence and improving the sustainability and administration of the immigration system.
A new national report by the Canadian Health Coalition and the Madhu Verma Migrant Justice Centre finds international students’ access to health care in Canada varies sharply by province/territory, creating a patchwork of public and private coverage that can leave students facing significant out-of-pocket costs despite Canada Health Act principles of reasonable access. The report identifies Alberta, New Brunswick, Northwest Territories, Saskatchewan and Prince Edward Island as providing the greatest access to free public coverage for international students, while Ontario, Manitoba and Yukon rely on private-only options; other jurisdictions impose waiting periods, fees, or eligibility restrictions (e.g., British Columbia’s three-month wait plus a monthly fee; Quebec limiting public coverage to students from countries with social security agreements). It also highlights practical barriers—limited system navigation support, cultural/language challenges, uncertainty about reimbursement—and illustrates how students can lose coverage during status transitions (e.g., after graduation or during permit renewals), with the report urging federal/provincial governments and post-secondary institutions to ensure more equitable access to public health insurance for international students.
IRCC announced that, consistent with Budget 2025, the Interim Federal Health Program will introduce co-payments for eligible supplemental health products and services effective May 1, 2026, meaning beneficiaries will pay $4 per eligible prescription filled/refilled and 30% of the cost of other eligible supplemental benefits (including dental, vision, counselling, and assistive devices), while basic benefits (e.g., doctor visits and hospital care) remain fully covered with no co-payments; IRCC also advises beneficiaries to use an IFHP-registered provider, confirm whether/what co-payment applies in advance, and keep receipts, with additional guidance available via an information toolkit and IFHP/Medavie Blue Cross resources.
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Canada Border Services Agency marked World Customs Organization’s International Customs Day by summarizing 2025 enforcement, immigration integrity, and trade facilitation results, including seizures of 83,211 kg of illegal drugs (up from 52,057 kg in 2024) and more than 17,700 prohibited weapons, interception of 1,590 stolen vehicles at export points, and facilitation of the removal of nearly 22,000 inadmissible individuals, alongside operational updates on border staffing (16,500+ employees and recruitment of 1,000 new officers) and trade/revenue administration through CARM, which the CBSA reports supported collection of $47.5B in duties and taxes in FY 2024–2025 and expanded portal use for over 213,000 registered businesses.
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IRCC updated its Ukraine-related program delivery instructions to remove outdated information and direct officers to the “Measures to support Ukrainians and their family members – post CUAET” instructions; the update refreshes multiple guidance pages covering CUAET-related overseas and in-Canada applications (including temporary resident visas/permits, extensions of temporary resident status, open work permits, and study permits), as well as general processing and the post–July 15, 2023 shift to regular temporary resident processing for Ukrainian nationals and their family members, and deletes the prior “Ukraine: Program-specific special measures” instructions.
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IRCC updated instructions under the temporary public policy facilitating permanent residence for certain foreign nationals affected by the conflict in Sudan with family in Canada, applying only to applications received on or after February 25, 2025.
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Issue: Whether an immigration officer’s refusal of a privately sponsored refugee application was reasonable, specifically regarding “plausibility” findings about the applicant’s fear of Al-Shabaab.
Facts: Mohamud Isse Artan applied for permanent residence as a refugee, claiming fear of Al-Shabaab. The officer refused the application, finding it “implausible” that his persecutors would warn him of a death threat rather than killing him immediately.
Court Findings: Justice Battista found the officer’s plausibility finding unreasonable. The court noted that persecutors (especially extortionists) do not always behave rationally or predictably, and plausibility findings should only be made in the “clearest of cases”.
Outcome: Application for judicial review granted. The decision was quashed and remitted for reconsideration by a different officer.
Why This Case is Important: It reinforces the high threshold for “plausibility” findings established in Valtchev v Canada. It serves as a reminder that Canadian decision-makers cannot impose “Western” standards of rational behavior on foreign persecutors or criminal organizations.
Issue: Whether a Citizenship Judge acted reasonably in granting citizenship to an applicant who exceeded the physical presence requirement by only 15 days, despite some evidence gaps.
Facts: Romeo Yaghi applied for citizenship, claiming 1,110 days in Canada (minimum required: 1,095). The Minister challenged the decision, citing a “missing” passport (Passport 908) and a mysterious “VIOPP” (visa in other passport) notation in his current passport.
Court Findings: Justice McHaffie dismissed the Minister’s challenge. The court held that the Citizenship Judge had “probed and elicited” evidence adequately and was entitled to find the applicant credible. The judge wasn’t required to be a “Monday morning quarterback” and catch every minor inconsistency.
Outcome: Application for judicial review dismissed. The grant of citizenship stands.
Why This Case is Important: It clarifies the role of the Citizenship Judge as both adjudicative and inquisitorial. It emphasizes that while “clear and convincing” evidence is needed for physical presence, credible testimony can be used to fill gaps in the documentary record.
Issue: Whether an Iranian national was entitled to costs and a specific processing location after his visitor visa was refused for a third time.
Facts: Alireza Fazlalizadeh had his visitor visa refused three times. In this third judicial review, the Minister conceded the decision was unreasonable. The applicant sought $5,000 in costs, alleging bias against Iranians.
Court Findings: The court granted the judicial review but denied the request for costs. There was no evidence of “special reasons” or bad faith. The court also refused to order that the case be processed at a specific embassy, as that remains within the IRCC’s discretion.
Outcome: Application for judicial review granted (by consent), but costs and specific redetermination instructions were denied.
Why This Case is Important: It reaffirms that costs in immigration matters are only awarded for “special reasons” (Rule 22), even if an applicant has faced multiple unreasonable refusals. It also clarifies that the court will not easily interfere with the Minister’s administrative discretion regarding which office processes a visa.
Issue: Whether an officer’s refusal of an H&C application reasonably considered the “best interests of the child” (BIOC) for a teenager with a learning disability.
Facts: A mother and her 17-year-old son from Jamaica applied for H&C status. The son has a learning-related speech impediment. The officer refused, using “boilerplate” language and even referring to the male child using “she/her” pronouns.
Court Findings: Justice Conroy found the decision unreasonable. The officer failed to perform a “global assessment” of the son’s specific vulnerabilities—his age, race, and disability, in the context of high gang-recruitment rates in his home parish.
Outcome: Application for judicial review granted. Matter remitted for redetermination.
Why This Case is Important: This case applies the Kanthasamy principle that officers must be “alert, alive and sensitive” to the BIOC. It highlights that misidentifying a child’s gender or ignoring a disability in a BIOC analysis can render a decision unintelligible.
Issue: Whether a former member of the Punjab Police was inadmissible to Canada for “complicity” in crimes against humanity.
Facts: Rattan Singh served in the Punjab Police/PAP for 23 years (1989–2012). The Immigration Division (ID) found that while he didn’t personally commit crimes, his role in transporting and investigating suspects during a period of widespread torture and extrajudicial killings made him complicit.
Court Findings: Justice Furlanetto upheld the ID’s decision. Applying the Ezokola factors, the court agreed there were “reasonable grounds” to believe he made a voluntary, knowing, and significant contribution to the police force’s criminal purpose.
Outcome: Application for judicial review dismissed. The deportation order stands.
Why This Case is Important: It illustrates the application of the Ezokola test for complicity. It shows that even a “lower rank” officer (like a Constable) can be found complicit if their duties place them in close proximity to the perpetration of crimes.
Issue: Whether an officer reasonably assessed the H&C application of an elderly Indian couple based on their “establishment” and “ties”.
Facts: An elderly couple (ages 62 and 63) came to Canada to help care for their grandson. The officer refused their H&C application, claiming they had only been in Canada for 1.5 years (they had actually been there for 3) and that they lived “60 years in India” (ignoring their 22 years in Greece).
Court Findings: Justice Thorne granted the review, finding the decision full of “factual and logical errors”. The officer clearly misapprehended the evidence regarding the couple’s history and health.
Outcome: Application for judicial review granted. Matter returned for redetermination.
Why This Case is Important: It emphasizes that “reasonableness review” requires the decision-maker to actually get the facts right. Miscalculating an applicant’s time in Canada by half is a reviewable error.
Issue: Whether a temporary resident visa refusal was reasonable and whether “special reasons” existed for a costs award.
Facts: Huanrong Zhang’s visa was refused because the officer wasn’t satisfied she had sufficient assets. The Minister conceded the decision was unreasonable. Zhang sought $5,000 in costs because the Minister “prolonged” the case by waiting until after leave was granted to settle.
Court Findings: The court allowed the judicial review but denied the costs. The Minister is entitled to wait for the certified record and for leave to be granted before settling; this is not “bad faith”.
Outcome: Application for judicial review granted (by consent); costs denied.
Why This Case is Important: Like Fazlalizadeh, this case confirms that the Minister’s decision to defend a judicial review initially and settle later does not automatically trigger an award of costs for the applicant.
Updated Forms and Checklists:
IMM 5373: Sponsorship Undertaking and Settlement Plan – Sponsorship Agreement Holders
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The content of this bulletin is for informational purposes only, and is not intended to provide or be relied on as legal advice.
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