This week, we had the privilege of celebrating yet another success at our office. This case highlights the complexities of citizenship applications and the importance of a strategic legal approach.
The Background
Our client, a business professional, had applied for Canadian citizenship. However, during the process, the client received two Procedural Fairness Letters (PFLs) from the immigration officer, who questioned the client’s eligibility and requested an extensive range of documents. The scope of the request was remarkably broad, requiring the client to submit:
- Bank statements from all financial institutions—both in Canada and internationally—for the entire duration of the client’s stay in Canada.
- Employment records and supporting documents from all past employers.
- Business ownership documents, including incorporation and registration records for any business owned in Canada or abroad.
- Housing records, such as rental agreements, leases, or mortgage documents covering the client’s entire period of permanent residence.
- Official educational records from all institutions attended in Canada.
- Proof of language proficiency, including any language tests taken.
The Challenge
This client responded to the first PFL herself and only asked for our help when the client received the second PFL. Our client had a complex financial and professional history. This client was involved in various business ventures both in Canada and China, held multiple corporate roles, and participated in self-employed and non-profit activities.
This client’s professional background, which spanned multiple business ventures in Canada and abroad, added to the complexity of the case. We needed to ensure a response that addressed the officer’s concerns without over-disclosing sensitive information.
Our Approach
Rather than simply submitting all requested documents without question or refraining from providing the required documentation, we took a strategic, rights-based approach by:
- Conducting a comprehensive document review: We analyzed hundreds of financial, business, and personal records to determine what was directly relevant to the citizenship application.
- Balancing compliance and client rights: While we provided all essential documents, we also sought clarification from the officer on the necessity of some requests that appeared excessive or unrelated.
- Preparing a compelling, well-structured submission: Our final package—over 300 pages—was meticulously organized to directly address the officer’s concerns while ensuring our client’s privacy was protected.
The Outcome
After weeks of detailed legal work and multiple client meetings, our efforts paid off. This morning, our client received a Notice to Appear: Ceremony to Take the Oath of Citizenship—a testament to our strategic and meticulous approach in responding to procedural fairness concerns.
Key Takeaways for Applicants and Representatives
For those facing similar challenges—whether as legal representatives or self-represented applicants—this case reinforces an essential reality:
❌ Templated, generic responses no longer work.
✅ Every submission must be 100% personalized, professionally drafted, and directly responsive to the officer’s concerns.
The recent Federal Court decision in Rezvani Gilkolaei v. Canada (Citizenship and Immigration), 2025 FC 194 (link), serves as a critical reminder that immigration authorities and judges are applying stricter scrutiny to applications. A strong response must be well-structured, legally sound, and backed by clear, relevant evidence.
At our firm, we understand the stakes of these applications and are committed to providing tailored, high-quality representation to ensure our clients’ success.
