Explore the latest ImmPulse Weekly for key Canadian immigration insights—or browse past editions to catch up.
Prime Minister Mark Carney said in London that Canada will court tech talent deterred by President Trump’s new $100,000 fee on fresh H-1B petitions, calling it an “opportunity” and promising a “clear offering” as Ottawa reviews its immigration strategy. The move positions Canada alongside the U.K. and Germany as alternative destinations for skilled workers affected by the U.S. changes. (Toronto Sun)
Canada’s population rose just 0.1% in Q2 2025 (+47,098 people), the lowest second-quarter growth since 1946 outside pandemic years, largely because non-permanent residents fell by 58,719, the largest non-pandemic quarterly drop since 1971; Ottawa’s 2024 policy changes curbing temporary foreign workers and study permits contributed, with fewer work/study permit holders partly offset by more asylum claimants; meanwhile, aging accelerated (average age 41.6 → 41.8; nearly 1 in 5 Canadians 65+). (CBC News)
Ottawa is projected to issue about 30% fewer PGWPs in 2025, roughly 143,600 versus 205,117 in 2024, driven by new language requirements, limits on joint public–private college programs, and field-of-study rules for non-degree programs. In the first half of 2025, approvals were 75,000 (-29% year-over-year), with May–June down more than 56%; a worst-case forecast puts 2025 below 130,000, the lowest since the pandemic. Distribution is shifting: 65% of permits went to college grads (undergrads just 9%, postgrads 17%); by field, 44% were in business/management, 15% computing/IT, 10% health/general science, 9% arts/social sciences/humanities, and 6% engineering. Top recipient nationalities Jan–Jun 2025: India (43,803), China (4,129), Nigeria (3,831), Philippines (3,418), Nepal (2,280), among others. (Toronto Star)
CBC reports that Liberal MP Vince Gasparro announced a ban on Kneecap citing a U.K. terror-related charge against member Mo Chara, but he did not brief Public Safety or the Privacy Commissioner beforehand; the charge was later quashed, and federal officials have refused to confirm any ban, citing privacy. Legal experts quoted say the privacy basis is debatable, the case for exclusion appears weak, and any real ban should be communicated by a formal decision letter, raising process and coordination concerns inside government. (CBC News)
Applications since May doubled to 1,400+, 140+ accepted offers, and 2,950+ expressions of interest since a March campaign targeting WA/OR/CA and U.S. academic outlets. The province fast-tracked licensing, 535 U.S. nurses and 104 NPs registered, and CPSBC bylaw changes allow U.S.-trained physicians to practise without extra exams/training (29 registered); B.C. also removed the LMCC exam for doctors trained outside Canada/U.S., with further streamlining proposed. Officials say these moves will bolster teams and reduce waits across the province. (Source)
Issue: Mandamus to compel a decision on a Start-Up Visa PR application pending 51 months, where processing of four “essential” team members is linked and one essential member is facing possible s.35(1)(b) inadmissibility (PFL issued).
Facts: Applicant applied in August 2020 under SUV; processing is tied to three other essential co-founders. IRCC security partners provided recommendations in August 2025; a PFL (September 18, 2025) raised potential s.35(1)(b) inadmissibility for one essential member.
Court Findings: Even if the 51-month delay is prima facie long, IRCC provided satisfactory justification because approval is contingent on all essential members; the Court would not impose a timeline that effectively dictates deadlines in another person’s file or hampers that person’s ability to respond to serious allegations. On the mandamus test (Apotex/Conille), the Applicant did not establish an unreasonable delay lacking justification or a clear, enforceable duty to issue a decision independent of outcomes in the essential member’s case; balance of convenience also not met.
Outcome: Application for JR/mandamus dismissed; no costs.
Why This Case is Important: This case is distinguished from the earlier judgment of the court, where it was held that security clearance for a co-applicant does not, on its own provide a sufficient justification for the delay in processing the Applicant’s application. [Majidi 2025 FC 680] The court has issued split decisions over the course of several months.
Issue: Whether IRCC could reject an Express Entry PR application at R10/R12 “completeness check” for not including a birth certificate of a non-accompanying dependent, despite the applicant having provided all required information about family members.
Facts: The Indian applicant (software developer, in Canada) received an ITA on December 8, 2023 and applied January 17, 2024, listing spouse/three children as non-accompanying. On April 4, 2024, IRCC rejected the package as incomplete for not including a dependent’s birth certificate; a GCMS note recorded “File does not meet R10… Dep 1 Birth Certificate – NOT Included.”
Court Findings: IRPR s.10(2)(a) requires information about family members (name, DOB, etc.), not specific documents proving those details. Conflating an “information” requirement with a “document” requirement was unreasonable. Departmental web instructions cannot narrow access beyond the Act/Regulations; reliance on them risks fettering discretion. Thus, returning the application under s.12 for incompleteness was not justified under Vavilov.
Outcome: Application granted; rejection set aside and remitted to a different officer; applicant may update the application before redetermination; no certified question.
Why This Case is Important: Strong authority that at the R10 completeness stage, missing “proof” documents (e.g., non-accompanying child’s birth certificate) are not, by themselves, fatal where the Regulations only require information; web guidance can’t substitute for law.
Issue: Whether the H&C refusal should be quashed where the Certified Tribunal Record (CTR) omitted the applicant’s H&C submissions.
Facts: PR on H&C was refused on November 23, 2024. On JR, the judge noted the CTR was missing the applicant’s H&C submissions (though appended articles were in the CTR).
Court Findings: From the bench, the Court granted JR after the Minister conceded, applying Togtokh scenario #2: a document known to have been properly submitted was absent from the CTR and it was unclear if it was before the decision-maker, warranting overturning the decision.
Outcome: JR granted; remitted to a different officer; applicant may re-file the H&C package; no certified question.
Why This Case is Important: Confirms that a deficient CTR, where known submissions are missing, undermines reasonableness and compels remittal (Togtokh scenario #2).
Issue: Whether an SUV PR refusal based on spouse’s inadmissibility for non-compliance (IRPA s.16(1), s.41) was reasonable.
Facts: Applicant’s SUV PR was refused after multiple PFLs sought clarity on the spouse’s schooling and employment; materials were inconsistent (police academy studies; shifting explanations; limited proof).
Court Findings: The officer did not speculate about police employment; rather, refusal rested on failures to provide clear, complete answers despite repeated opportunities. The onus lay with the applicant; officers are owed deference.
Outcome: JR dismissed; no certified question.
Why This Case is Important: Reinforces duty of candour and applicant’s burden to resolve discrepancies; courts won’t reweigh evidence where officers transparently ground findings in inconsistent, incomplete responses.
Issue: Whether the H&C decision unreasonably assessed hardship tied to the applicant’s mental illness in Nigeria.
Facts: A 23-year-old Nigerian sought H&C based on hardship and establishment; refusal issued March 15, 2024.
Court Findings: Unreasonable to infer adequate care from identifying one agency (“Lagos Mind”) without grappling with contrary country-condition evidence; unreasonable to dismiss stigma concerns as “speculative” given evidence that symptoms may involuntarily manifest.
Outcome: JR allowed; remitted to a different decision-maker; no certified question.
Why This Case is Important: H&C hardship analyses must engage the record and country evidence on availability/access to mental-health care and stigma; optimistic snippets cannot substitute for a rational chain of analysis.
Issue: Whether the OWP refusal was reasonable where IRCC requested “information and/or documentation,” and the applicant’s reply letter (providing information) appears not to have been considered.
Facts: Applicant (in Australia) applied for an OWP (LMIA in place). Officer refused for temporary status and ability to perform duties; “new” oral arguments barred because not advanced in further memorandum.
Court Findings: The August 18, 2024 reply plainly provided “information,” yet the officer appears not to have considered it; decision therefore unreasonable under Vavilov.
Outcome: JR allowed; set aside; remitted to a different officer; no certified question.
Why This Case is Important: Even where “documents” are missing, an officer must consider substantive “information” provided in response to an IRCC query framed as “information and/or documentation.”
Issue: Whether a TRV refusal was reasonable where reasons contradicted record evidence on purpose, ties, and funds.
Facts: Iranian applicant/20% business owner sought to attend meetings; refusal stated the invitation had “passed,” downplayed ties abroad, and questioned funds.
Court Findings: Officer ignored letter detailing upcoming meetings; discounted clear ties in Iran/Cyprus; found insufficient funds despite evidence of ~CAD 220,000; post-hoc reliance on Ankara VO bank-history guidance rejected.
Outcome: JR allowed; set aside; remitted; no certified question.
Why This Case is Important: TRV reasons must “add up” to the record; courts will not accept after-the-fact bolstering with VO guidance absent contemporaneous reasoning.
Issue: Whether TRV refusals for Iranian parents were reasonable where reasons were boilerplate and failed to engage financial evidence.
Facts: Parents sought to visit two student daughters; refusal cited insufficient assets/finances and purpose inconsistent with a temporary stay.
Court Findings: Officer did not mention or assess pension statements, bank summaries, property deed; post-hoc reliance on Iran-specific six-month bank history guidance rejected; reasons too “bare bones” to permit review.
Outcome: JR granted; remitted to a different officer; no certified question.
Why This Case is Important: Even under minimal-reasons context for TRVs, officers must show engagement with central evidence; generic templates are inadequate.
Issue: Whether a 17-year-old’s TRV refusal was reasonable where the officer offered virtually no explanation and ignored temporariness evidence.
Facts: Iranian high-school student sought to visit immediate family (incl. unwell brother); refusal letter said purpose inconsistent with a temporary stay.
Court Findings: Court refused to “buttress” reasons post-hoc; absence of analysis on evidence of temporariness made the decision non-transparent, unintelligible, and unjustified.
Outcome: JR allowed; set aside; remitted; no certified question.
Why This Case is Important: Reaffirms no after-the-fact bolstering and that even brief TRV reasons must show some weighing of temporariness evidence, especially for youth visiting family.
Issue: (1) Was the spousal PR refusal reasonable? (2) Was procedural fairness breached by not interviewing or issuing a PFL?
Facts: Spousal sponsorship filed December 16, 2023; IRCC requested further documents July 30, 2024; applicant responded August 27, 2024; refusal September 18, 2024.
Court Findings: Genuineness is highly factual and owed deference; the record showed limited relationship proof, inconsistencies, minimal financial interdependence, and weak messaging/photo evidence; fairness was satisfied by the evidence-request letter, no duty to interview.
Outcome: JR dismissed; no certified question.
Why This Case is Important: Clarifies that officers may decide spousal genuineness without interviewing; applicants must present complete, convincing evidence up front.
Issue: Whether an HSW-Class PR refusal, focusing on principal applicant’s ability to perform the work and employer’s ability to fulfill the offer, and denial of a 60-day extension were reasonable/fair.
Facts: Applicants applied under HSW; PFL identified concerns re: applicant’s ability and employer viability; applicants sought extra time to secure a new job offer; refusal followed.
Court Findings: No reviewable error: extension to find a different employer would not cure core deficiencies; officer’s decision was justified and procedurally fair under Vavilov.
Outcome: JR dismissed; no certified question.
Why This Case is Important: Confirms HSW selection focuses on both ability to perform and employer capacity; extension requests must address the PFL-identified deficiencies, not pivot to a new employer.
Issue: Whether IRCC’s refusal to re-open/reactivate a finalized PR file (after landing window lapsed) was unreasonable, where the real challenge targeted the earlier extension refusal.
Facts: PR finalized July 25, 2022 (CoPR/visa valid to June 22, 2023). Extension request (June 14, 2023) denied June 28, 2023; over a year later the applicant sought reactivation; IRCC refused August 29, 2024.
Court Findings: Applicant’s submissions effectively attacked the (unchallenged) extension decision, not the re-open decision; that does not undermine the latter’s reasonableness. JR limited to the decision under review.
Outcome: JR dismissed.
Why This Case is Important: Outlines the limits of reconsideration/re-opening: you cannot backdoor a challenge to an earlier, un-reviewed decision (like an extension refusal) via later reconsideration JR.
Issue: Whether IRCC’s refusal of a Home Child Care Provider Class (HCCPC) PR application, based on concerns about the genuineness of the job offer, the employer’s ability to pay, and indications of multiple concurrent job offers, was reasonable and procedurally fair.
Facts: The principal applicant (with family) applied under HCCPC in December 2021, supported by a private-household employer. In November 2023, an IRCC agent noted no financial/supporting documents and that the employer appeared to have multiple job offers under the same profile. IRCC wrote the employer seeking proof of ability to pay and, specifically, answers about multiple caregivers/offers. The employer sent tax documents but did not address the “multiple caregivers” questions. IRCC told the applicants the offer did not appear genuine because not all requested information had been provided; the applicants then resubmitted the same employer materials. The application was refused on April 3, 2024.
Court Findings: Reasonableness. The officer’s focus on genuineness, necessity of a caregiver, and ability to pay falls squarely within HCCPC selection criteria; GCMS notes supplied an evidentiary basis for the “multiple job offers” concern; the officer made no veiled credibility finding because the employer never actually addressed the multiple-offers point.
Procedural fairness. Applicants were informed of concerns and given 30 days. There was no duty to disclose the “multiple offers” concern in advance beyond what was already communicated; applicants elected to respond immediately and simply resubmitted prior material.
Outcome: JR dismissed; decision found reasonable and procedurally fair; no certified question.
Why This Case is Important: Confirms deference to HCCPC genuineness assessments where GCMS-recorded concerns are put to the parties and not substantively addressed; no obligation to micro-itemize every specific deficiency if applicants had a meaningful chance to respond.
For comprehensive legal analysis or strategic case support, contact Greenberg Hameed PC.
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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