Does a PRRA Applicant Need Documentary Evidence to Corroborate Their Sworn Statement?
Not always. In a Pre-Removal Risk Assessment (“PRRA”), an immigration officer may err by requiring documentary evidence to corroborate a sworn statement where there is no reason to doubt the applicant’s truthfulness.
In Mizi v Canada (Citizenship and Immigration), 2026 FC 1038, the Federal Court considered an applicant’s solemnly declared written statements concerning his support for and membership in the KSJL.
The Officer did not identify any reason to doubt the truthfulness of those statements. The Court found that, in those circumstances, “it would have been an error to require such corroborative evidence,” citing Ndjavera v Canada (Citizenship and Immigration), 2013 FC 452 at paras 6–7. The Court also relied on the established principle discussed in Chekroun v Canada (Citizenship and Immigration), 2013 FC 737 at para 65:
“It is settled law that when a claimant swears to the truth of his testimony, that testimony is presumed to be true unless there is a valid reason to doubt its truthfulness.”
The principle originates from Maldonado v Canada (Minister of Employment and Immigration), [1980] 2 FC 302 (CA).
What Does This Mean for PRRA Applicants?
A lack of corroborating documents does not necessarily permit a PRRA officer to disregard sworn evidence. If an officer does not identify a valid reason to doubt the truthfulness of an applicant’s sworn statement, requiring additional corroboration may be unreasonable.
If your PRRA application has been refused because an officer found that you did not provide sufficient corroborating evidence, contact our office to discuss whether the decision may be challenged through judicial review in the Federal Court.
