Ontario Review Board
Re: Abdirahaman Abdulle
ORB File No: 3366/6569
Hearing held on: Tuesday, September 23, 2025
Place of hearing: Centre for Addiction and Mental Health 1001 Queen Street West, Toronto
Pursuant to: Section 672.81(1) of the Criminal Code
Before: Alternate Chairperson: Ms. M. Labrosse Members: Dr. B. Sheppard Dr. G. Eayrs Mr. M.D. Segal Mr. W. Apted
Parties Appearing: Accused: Abdirahaman Abdulle Counsel: Ms. M. Addie
The person in charge of hospital: Counsel: Ms. S. Rosales-Zelaya
Attorney General of Ontario: Counsel: Mr. C. Coughlan
REASONS FOR DISPOSITION
(Dated November 5, 2025)
Introduction
On May 9, 2001, Mr. Abdirahaman Abdulle was found not criminally responsible on account of mental disorder on a charge of uttering death threats, contrary to the Criminal Code of Canada.
On July 3, 2014, Mr. Abdirahaman Abdulle was again found not criminally responsible on account of mental disorder on a charge of assault with a weapon, contrary to the Criminal Code of Canada.
Mr. Abdulle is currently subject to a disposition of the Ontario Review Board dated September 12, 2024, which detains him at the Forensic Service of the Centre for Addiction and Mental Health, Toronto, with privileges up to and including to live in the community in 24-hour a day supervised accommodation approved by the person in charge.
On September 23, 2025, the Ontario Review Board (“ORB”) convened a hearing at the Centre for Addiction and Mental Health, Toronto, (“CAMH” or the “hospital”), to review Mr. Abdulle’s last disposition, pursuant to s. 672.81(1) of the Criminal Code. Mr. Abdulle was present for the hearing and was represented by his counsel, Ms. M. Addie. An updated Hospital Report dated September 12, 2025, was entered as Exhibit 1 for the hearing.
The issues for this hearing are whether Mr. Abdulle continues to meet the threshold for significant threat to the safety of the public, and if so, to determine the necessary and appropriate disposition for the coming year.
At the outset of the hearing, the parties presented the Board with a joint position based on the hospital recommendation for the maintenance of the current disposition. That joint position was maintained at the conclusion of the hearing.
For the reasons set out below, the Board finds that Mr. Abdulle continues to pose a significant threat to the safety of the public and that the maintenance of the current disposition, namely a detention order with community living in 24-hour supervised accommodation, remains the necessary and appropriate and least onerous and least restrictive disposition in all of the circumstances.
Index Offences
- The circumstances giving rise to the index offence are extracted from last year’s Board Reasons, as follows:
“Police reports indicated that on October 7, 1996, Mr. Abdulle called a female cousin on the telephone. Mr. Abdulle accused his cousin and her ex-spouse of owing him a hundred and twenty thousand dollars. She stated that neither owed him any money. Mr. Abdulle stated that he was going to kill her and her four children. He said that he had a gun and was going to go to her home, break her windows, and take her away. The woman called the police.
Mr. Abdulle was not located until February 12, 1997. On that date Mr. Abdulle came to the attention of the police after he was found running naked through an apartment building. After being detained, he apparently removed his clothes again and sat naked in his cell. He was assessed by Dr. Dickey at METFORS and was deemed to be unfit to stand trial. He returned to court and was found unfit to stand trial on March 6, 1997. He was sent to the Mental Health Centre, Penetanguishene, Oak Ridge Division (MHCP) on June 12, 1997.
Mr. Abdulle was found fit to stand trial on March 12, 2001, and sent back to Metro West Detention Centre. He was found not criminally responsible on May 9, 2001.
The second index offense occurred on Sunday, December 22, 2013, at approximately 12:45 PM. The victim in this matter was a registered nurse who worked at CAMH for 31/2 years and was assigned to Unit 1-3. The victim was attempting to give medication by injection to Mr. Abdulle. Mr. Abdulle refused, stating “If you do that, you are my enemy. Whoever does that is my enemy.” The victim contacted security and at 1:40 PM Mr. Abdulle agreed to comply. As the victim escorted Mr. Abdulle to the treatment room, Mr. Abdulle suddenly lashed out, stabbing the victim in the side of the head with a pen. The victim sustained a laceration to the right side of the face, requiring 3 stitches."
Background History
- Mr. Abdulle’s personal, legal and psychiatric history are set out in detail in the Hospital Report and are accurately summarized in last year’s Reasons as follows:
Criminal History:
“August 10, 1992: Assault with a Weapon Mischief over $1,000 Fail to Appear in Court Assault
July 22, 1994: Possession of Property Obtained by Crime Uttering Threats
April 13, 1995: Uttering Threats
September 27, 1996: Uttering Threats Assault with a Weapon
October 2, 2011: Assault Causing Bodily Harm
Mr. Abdulle’s personal history is found in detail in the Hospital Report which was filed as an exhibit. Mr. Abdulle was born in Ethiopia and has eight brothers and sisters. His mother continues to reside in Somalia, and he has a sister who lives in Missouri. He has an uncle and cousins who reside in the Toronto area. Mr. Abdulle came to Canada in 1986. It is reported that Mr. Abdulle has an informal education somewhere between grade 8 and grade 12, completed in Somalia. He has not been employed in Canada since approximately 1989 and has been on ODSP since then.
Mr. Abdulle has a psychiatric treatment history dating back to March of 1988, commencing at Etobicoke General Hospital. He also has had admissions to Queensway General Hospital in Ottawa, the Clarke Institute of Psychiatry and to North Bay Psychiatric Hospital. The records indicate that Mr. Abdulle typically left treatment by eloping or leaving against medical advice. His history also indicates that he was noncompliant with recommendations for follow up and treatment with antipsychotic medication.”
- Mr. Abdulle’s current diagnosis is schizophrenia – paranoid type.
Evidence at the Hearing
The hospital’s evidence was presented through its report and through the oral testimony of Dr. S. Durani. This evidence is summarized below.
Dr. Durani is Mr. Abdulle’s treating psychiatrist on the general forensic unit D (FGUD) where Mr. Abdulle has been residing since August 13, 2021. Dr. Durani adopted the contents of the Hospital Report and advised that there were no material updates since its completion.
With respect to highlighting Mr. Abdulle’s last reporting year, Dr. Durani stated that it was an overall positive year with some ongoing issues regarding Mr. Abdulle’s ability to follow staff direction and that Mr. Abdulle continues to exhibit residual symptoms of his illness. According to Dr. Durani, Mr. Abdulle continues to require much external supports because of his many deficits. Mr. Abdulle’s ongoing deficits include his lack of insight and his history of acting out aggressively.
With respect to community living, Mr. Abdulle will require 24-hour supervised accommodation to provide the ongoing structure and medication supervision that is required to manage his risk.
In response to questions posed to her by counsel for the Attorney General, Mr. Coughlan, Dr. Durani confirmed that Mr. Abdulle continues to experience auditory hallucinations in the form of “shushing” which continue despite treatment. Mr. Abdulle was given a medical follow-up to rule out a medical etiology, and it remains the opinion of the treatment team that this is an auditory hallucination and symptom of his schizophrenia.
Dr. Durani stated that Mr. Abdulle was referred for a medication consultation for his ongoing symptoms which consultation was conducted by Dr. LeBlanc who is a consulting psychiatrist at the Schizophrenia Program at CAMH. Dr. LeBlanc recommended clozapine, as an alternative treatment, or increasing the dose of medication and/or engaging in ECT treatments as possible ways of better treating Mr. Abdulle’s symptoms. In consultation with Mr. Abdulle’s substitute decision maker, who is his second cousin, the SDM declined to make any treatment changes at this time though the hospital will continue to engage in conversations on this issue.
In response to questions posed to her by counsel for Mr. Abdulle, Ms. Addie, Dr. Durani explained that the treatment team is still working to find appropriate housing for Mr. Abdulle. Mr. Abdulle has been designated for ALC (Alternative Level of Care) which may assist in moving him sooner as this opens the possibility other housing options. This designation was in place at the time of last year's hearing before the Board. The treatment team has also explored the possibility of DSO funding for Mr. Abdulle who underwent a psychological assessment to determine whether he would qualify. The assessment concluded that Mr. Abdulle’s presentation is not consistent with an underlying intellectual disability, and therefore, he does not qualify for DSO funding.
Dr. Durani confirmed that Mr. Abdulle is on the Access Point waitlist but that because of his significant needs, no suitable housing has yet been identified. In addition, the treatment team pursued a long-term care application; however, Mr. Abdulle was found to be ineligible for this housing based on his age and level of functioning. Dr. Durani added that the treatment team can reapply for LTC housing in the future and that this could become an option for Mr. Abdulle if there are changes in his presentation and with advanced aging, all of which may render him eligible in the future for long-term care housing.
Responding to a question from Ms. Addie, Dr. Durani confirmed that the treatment team would be aware of any new initiatives for challenging housing and that those options would be necessarily pursued for Mr. Abdulle.
Mr. Abdulle has been exercising Level 5 privileges which allow him to go out in the community with an approved person. His cousin, also his SDM, is an approved person and Mr. Abdulle goes out with him on average once per month. Dr. Durani added that those passes have recently been increased from 4 to 8 hours in the last year.
In response to questions posed by members of the panel, Dr. Durani stated that the hospital is hopeful that Mr. Abdulle can continue to move up the pass ladder though there are still concerns about his ability to follow directions and his navigation skills in the community. The treatment team will continue to evaluate this on an ongoing basis. Dr. Durani could not confirm whether it would be realistic for Mr. Abdulle to graduate to unaccompanied passes in the next year.
Dr. Durani stated that the treatment team has noted a decline with respect to Mr. Abdulle’s cognitive and adaptive functioning. The neurological assessment finding is that the decline is likely attributable to Mr. Abdulle’s chronic schizophrenia. This suggests that Mr. Abdulle’s prognosis and trajectory for the future are guarded.
Dr. Durani was asked how she communicates with Mr. Abdulle given the language barrier and she indicated that Mr. Abdulle’s understanding of English is quite good, but he does have difficulty expressing his needs. Dr. Durani confirmed that Mr. Abdulle is involved in many recreational activities, that he participates in several programs on the unit including cooking and meditation. Mr. Abdulle has not been noted to have any established connections with other co-patients and Dr. Durani stated that his interactions with others tend to be quite superficial.
Dr. Durani was asked whether it continues to be necessary to have urine drug screening requirements in the disposition. Dr. Durani acknowledged that, to his credit, Mr. Abdulle’s drug screens have been negative during the period; however, the screening is in place and recommended to remain in place because of a history of alcohol use in the context of aggressive and violent behaviour. Dr. Durani believes that the screening acts as a sort of deterrent to some extent and that Mr. Abdulle could be vulnerable to suggestions from other peers who might use substances.
The hospital risk assessment is set out at pages 41 to 43 of the Hospital Report and Mr. Abdulle’s re-offence scenario can be summarized as follows:
“Overall, if Mr. Abdulle were to reoffend, this would likely transpire in the following way: absent the supervision of the treatment team and the ORB, he would be extremely likely to discontinue his antipsychotic and mood stabilizing medications due to a combination of lack of insight into his illness as well as his conviction that medications are incompatible with his religious beliefs. As a result, his residual paranoid delusions would intensify, he would become increasingly agitated and disinhibited, and he would act out violently and aggressively in response to both his paranoid beliefs and his mounting agitation. He would be further disinhibited by his underlying antisocial traits, as well as any resumption of substance use, such as alcohol, which he has used excessively in the past.”
- No other evidence was presented.
Analysis and Conclusion
Having considered all of the evidence presented at the hearing, and the joint submission of the parties, the Board finds that Mr. Abdulle continues to pose a significant threat to the safety of the public as set out in s. 672.5401 of the Criminal Code of Canada and as further defined in Winko v British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625.
According to R. v. Winko, a ‘significant threat to the safety of the public’ means a real risk of physical or psychological harm to members of the public that is serious in the sense of going beyond the merely trivial or annoying. The conduct giving rise to the harm must be criminal in nature. Further, it is noted that evidence to determine whether an individual is a significant threat to the safety of the public can include the past and expected course of the NCR accused’s treatment, if any, the present state of the NCR accused’s medical condition, the NCR accused’s own plans for the future, the support services existing for the NCR accused in the community, as well as other items.
Mr. Abdulle suffers from schizophrenia, and despite treatment, he continues to have residual symptoms. Mr. Abdulle has a history of assaultive behaviour when unwell, and when experiencing delusional beliefs. He has little insight into his illness and the need for treatment, and without the oversight of a Board disposition, is likely to discontinue treatment, leading to the intensification of his symptoms and the strong likelihood that he would eventually act out aggressively.
Mr. Abdulle has been in hospital for several years and would be ready for discharge to community accommodation with high supports and medication oversight. Mr. Abdulle’s many deficits, notably his lack of insight and difficulty following direction, require housing that is not readily available. The hospital has explored many options for housing and will continue to do so in the hope of finding suitable accommodation for Mr. Abdulle. This may include reapplying for long term care in the not-too-distant future.
In the meantime, Mr. Abdulle’s needs are being properly met in hospital where he is enjoying privileges including accompanied community passes with this cousin (SDM) and he is taking full advantage of recreational programs available to him.
Further to a medication consultation, options have been proposed to optimize Mr. Abdulle’s treatment and better treat his symptoms, but his SDM has opted not to make any changes at this time. The hospital will continue to discuss treatment options with Mr. Abdulle’s SDM.
We find that the joint position before for the maintenance of the current detention order is reasonable.
Having considered the factors as set out in s. 672.54 of the Criminal Code, namely the protection of the public, which is the paramount consideration, the mental condition of the accused, his reintegration into society and his other needs, the Board finds that the current detention order on the same terms and conditions remains the necessary and appropriate, least onerous and least restrictive disposition in all of the circumstances.
DATED this 5^th^ day of November, 2025, at the City of Toronto, in the Region of Toronto.
Ms. M. Labrosse Alternate Chairperson
__________________ Office of the Registrar Ontario Review Board