Your right that age alone doesn't require a Cody letter. More so in that it is a generic carbine.
But for several reasons it would be good to establish some provenance for this rifle. I believe there is enough verbal history to establish that this gun has been in Canada with the same family since new. So given that the 32 special represented a relatively small percentage during that first year and given that the number of 94's sold in Canada at the turn of the century was infinitely smaller.
What I'm getting at is this could be one of the oldest if not the oldest 32 special sold in canada. Which would certainly give the family something to cherish as they take their great grandfathers rifle deer hunting every year.