The Federal Court dismissed a Ghanaian midwife’s challenge to the refusal of her Canadian study permit application. In Study Permit Financing, the Court found the officer’s concerns about the purpose of the proposed studies and the evidence for available funds were reasonable.
Study permit application and refusal
Anokye v. Canada (Citizenship and Immigration), 2026 FC 1179, was decided by Mr. Justice Norris on September 21, 2026. The applicant, a 34-year-old citizen of Ghana, had applied in April 2025 for a study permit to complete the in-person clinical portion of the Internationally Educated Midwives Bridging Program at the University of British Columbia.
The applicant was employed as a Senior Staff Midwife in Ghana and planned to take a one-year unpaid leave. She stated that the program would give her skills and training she could use when returning to Ghana to continue her midwifery work.
The program required 12 weeks of online courses followed by at least 22 weeks of clinical placements in Vancouver. The applicant had completed the online component and had prepaid $5,635 of the $9,500 program fee before applying to undertake clinical training between January and June 2026.
An IRCC visa officer refused the application on May 12, 2025, because they were not satisfied that the applicant would leave Canada at the end of her authorized stay. The officer found that the purpose of the visit was not consistent with a temporary stay and that the applicant had not sufficiently established her financial capacity to support the proposed studies.
Applicant challenged purpose and financial findings
The applicant sought judicial review under the Immigration and Refugee Protection Act, arguing that the refusal was unreasonable. The parties agreed that the applicable standard of review was reasonableness.
On the purpose of study, the officer had questioned why the applicant would leave stable employment as a senior midwife to pursue the credential at significant cost. The officer also found that she had not established how the credential would provide an employment benefit in Ghana.
On finances, the applicant relied on a joint Ecobank account with a final balance of US$34,185.12, Eurobond holdings of US$57,981 and Treasury Bill investments equivalent to CAD$102,769. Her husband had undertaken to cover her study costs. The officer found there was no evidence showing how the husband had accumulated the Eurobond holdings or Treasury Bill savings.
Court found the officer's reasoning reasonable
Justice Norris held that the officer’s reasons were sufficient when read alongside the evidence in the application. The Court noted that the program’s acceptance letter described it as training for internationally educated midwives seeking to practise in Canada. It was a non-credit program that would lead to a completion form being sent to the British Columbia College of Midwives for registration eligibility.
The Court found that the applicant had not directly addressed that Canadian-practice focus in her study plan. There was also little evidence that the program taught many of the particular subjects and skills she said she hoped to gain, or that it would meaningfully add to her existing training and work experience in Ghana.
Regarding finances, the Court held it was not unreasonable for the officer to be concerned about the absence of evidence on the source of a significant portion of the funds relied on. The applicant’s husband stated that he was financially able to cover her expenses, but there was no evidence of how he was able to do so, including whether he was employed. There was also no evidence of the applicant’s income from her midwifery position.
The applicant argued that the joint bank account alone was enough to fund her studies. The Court disagreed that this undermined the refusal. It said the application had relied on the additional financial sources, making it reasonable for the officer to scrutinize them. The officer had not been asked to assess the joint account separately, and there was no evidence of the family’s regular expenses.
Judicial review dismissed
The Federal Court dismissed the application for judicial review. No serious question of general importance was proposed for certification, and no question was stated.
The Court noted that the applicant could apply again for a study permit and that evidence addressing the concerns raised by the officer could help her satisfy a future decision-maker. The judgment is based on the particular application record and does not direct a general change to study permit assessment practices.
Source: Federal Court Decisions