The Federal Court dismissed Duanmei Dong’s application for judicial review of a refused Pre-Removal Risk Assessment (PRRA) on September 14, 2026. In PRRA Religious Persecution, the Court found the officer reasonably gave little weight to a letter intended to corroborate her fear of persecution in China because of her Christian faith.
PRRA refusal followed claim of risk in China
Justice Pentney heard the matter in Dong v. Canada (Citizenship and Immigration), 2026 FC 1158. Dong sought review of a negative PRRA decision after claiming that she would face persecution in China because of her Christian faith.
The Court’s reasons state that Dong was not eligible to make a refugee claim in Canada because she had previously claimed asylum in the United States. She was instead offered a PRRA and attended a mandatory interview with the officer.
Dong said she began attending a house church in China after recovering from COVID-19. She claimed that a friend, Huizhen, who had introduced her to Christianity, was detained and questioned by police in 2022. Dong said the arrest caused the church gatherings to stop and led her to hide before travelling to Canada, where she attended Living Stone Assembly Church and was baptized in 2022.
Letter from friend was central evidence
The officer accepted that Dong attended church and was baptized in Canada, but found that her evidence did not establish a risk of persecution for practising her faith in China. The officer also found little evidence that her activities in Canada would have come to the attention of Chinese authorities.
A letter from Huizhen was the key corroborating document. It described arrest, detention and a requirement to report to police monthly. The officer assigned the letter little weight because it was not accompanied by a warrant, summons or other corroborating evidence, and because of contradictions in Dong’s evidence about why Huizhen was arrested.
Dong argued that the officer could not reasonably discount the letter for a lack of supporting documents. She submitted that there was no evidentiary basis to assume she would possess a summons or warrant, and that the finding was central enough to render the overall PRRA decision unreasonable.
Court found officer's evidence assessment reasonable
The Court reviewed the decision for reasonableness under the framework in Vavilov and Mason. Justice Pentney noted that a reviewing court generally cannot reweigh or reassess evidence considered by the administrative decision-maker.
Justice Pentney found the officer’s treatment of Huizhen’s letter intelligible and grounded in the record. Dong did not have first-hand knowledge of Huizhen’s interactions with police, and the letter itself was brief and general. It did not identify who detained or interrogated Huizhen, explain how she knew she was under surveillance, or provide details about the monthly reporting.
The Court also noted that the letter was dated January 15, 2025, while describing events from mid-May 2022. In the circumstances, the officer reasonably concluded that the letter should receive little weight.
Dong further argued that the officer’s findings were internally inconsistent because the officer accepted that unregistered house churches are prohibited in China while concluding that Dong had not shown she would be unable to practise her faith there. The Court rejected that argument, finding that the officer’s principal conclusion was that there was no indication Dong’s religious practice had attracted, or was likely to attract, the attention of state authorities.
Application dismissed without certified question
The Federal Court dismissed the application for judicial review. Justice Pentney found no exceptional circumstances that would justify revisiting the officer’s weighing of the evidence.
No question of general importance was certified. The decision addresses the reasonableness of this PRRA assessment on its record and does not direct a broader change to PRRA decision-making.
Source: Federal Court Decisions