Possibly. The refund from college can be taxable income if it was from scholarships and grants so he should fill out the return, enter his 1098-T (to show the amount of the refund) and see if he has a tax liability or taxable income. If he does, then he will need to file.
It the refund was because of student loans and not scholarships or grants, then no he does not need to file a return.
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