Ontario Review Board
Re: George A. Paragh
ORB File No: 6429
Hearing held on: Friday, November 14, 2025
Place of Hearing: Ontario Shores Centre for Mental Health Sciences
Pursuant to: Sections 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. C. Flanagan
Members: Dr. S. Lessard Dr. T. Stirpe Ms. L. Silver Ms. B. Naegele
Parties Appearing:
Accused: George A. Paragh Counsel: Ms. J. Boissonneault
Person in charge of hospital: Counsel: Ms. A. Marshall
Attorney-General of Ontario: Counsel: Ms. N. MacDonald
REASONS FOR DISPOSITION
(Dated December 15, 2025)
Introduction
1. On November 7, 2013, George A. Paragh was found not criminally responsible on account of mental disorder (“NCR”) on a charge of aggravated assault contrary to the Criminal Code of Canada (Criminal Code).
2. Mr. Paragh is currently subject to a Disposition of the Ontario Review Board ((“ORB” or “the Board”), dated December 3, 2024, by which he is ordered to be detained within the Forensic Service at Ontario Shores Centre for Mental Health Sciences (“Ontario Shores” or “the Hospital”) with privileges up to and including to live in the community in 24 hour a day supervised accommodation approved by the person in charge.
3. On November 14, 2025, a panel of the Board convened to review Mr. Paragh’s Disposition in accordance with the requirements of s. 672.81(1) of the Criminal Code.
4. Mr. Paragh and his counsel, Ms. J. Boissonneault, attended the hearing. A Hospital Report, dated October 17, 2025, was filed as Exhibit 1 at the hearing.
5. The issue to be determined is whether Mr. Paragh continues to represent a significant threat to the safety of the public, as defined in section 672.5401 of the Criminal Code, and if so, the necessary and appropriate Disposition to manage that risk, having regard to the criteria set out in s. 672.54 of the Criminal Code.
Initial Position of the Parties
6. At the outset of the hearing, the parties were canvassed as to their recommendations to the Board.
7. Ms. Marshall, on behalf of the Hospital, recommended no change to the current Disposition.
8. Ms. MacDonald, on behalf of the Attorney General of Ontario, supported the Hospital’s position.
9. Ms. Boissonneault, on behalf of Mr. Paragh, supported the continuation of the current Disposition and advised that significant threat was not in issue. She stated, however, that Mr. Paragh wished to live more independently and asked for clause 2(g) of his Disposition to be changed to remove the requirement for 24/7 supervision.
Index Offence
10. The circumstances of the index offences are taken from last year’s Reasons for Disposition, dated December 17, 2024, as follows:
“The aggravated assault was committed in 2012. Mr. Paragh assaulted a panhandler in the town of Ajax. The victim was panhandling and approached Mr. Paragh to solicit change. This angered Mr. Paragh, who then struck the victim with two closed fist punches to the head and face. The victim fell to the ground causing significant injury to his nose and head area. Mr. Paragh was then followed by witnesses and was identified to police by these witnesses and arrested Mr. Paragh a short time later. This veracity of the assault was such that the victim was rushed to the hospital as he had suffered a brain bleed.”
Personal Background/Developmental History
11. Mr. Paragh’s personal background and developmental history are set out in the Hospital Report, filed as an exhibit at the hearing, and need not be repeated here.
12. Briefly, Mr. Paragh is a thirty-nine-year-old male and is one of six siblings who were born in Jamaica. He completed sixth grade and came to Canada with his family in 2003, when he was seventeen.
13. Mr. Paragh is diagnosed with an intellectual disability with moderate severity. His mother reported that she first started noticing significant gaps in knowledge and intellectual ability when Mr. Paragh was in Jamaica. He was never able to spell his name, give his date of birth, know his address, understand the value of currency, or answer questions properly.
14. Mr. Paragh has no history of hospital admissions or substance use. Before the index offence, his sole hospitalization was in 2008 when police took him to the emergency department after he went missing and was found wandering.
15. In 2009, Mr. Paragh was charged with possession of property obtained by crime under $5000, shoplifting and obstruct/resist police, all of which were withdrawn as a result of court diversion.
16. Following the commission of the index offence of aggravated assault, Mr. Paragh was initially found unfit to stand trial. He eventually became fit and was returned to court. He was maintained on a “keep fit” order until November 7, 2013, when he was found NCR and transferred to Ontario Shores under the jurisdiction of the Ontario Review Board.
17. Mr. Paragh has a low tolerance and frustration level owing to his cognitive deficits. In this regard, under the jurisdiction of the Review Board, he has a history of both assaultive behaviour and destruction of property.
18. In April 2019, he was discharged to Christian Horizons, a highly supervised group home geared towards individuals with Dual Diagnosis. He was re-admitted to a secure forensic unit just over a month later due to significant environmental aggression, property destruction, and elopement.
19. In February 2024, he was discharged to Karis Housing (formerly known as Christian Horizons) but was returned to hospital following an alleged incident of violence in the community, detailed below.
20. He remains incapable of making decisions related to the treatment of his mental illness. The Office of the Public Guardian and Trustee (OPGT) act as his substitute decision-maker (SDM).
Current Diagnosis
21. Mr. Paragh’s diagnosis is intellectual disability (moderate severity).
Evidence at the Hearing
22. The Hospital’s evidence was presented through the oral testimony of Dr. L. Wong to supplement the Hospital Report, filed as an exhibit at the hearing.
23. Mr. Paragh had a challenging reporting year. At the beginning of the year, Mr. Paragh resided at Karis Housing, a 24/7 supervised and supported accommodation in the community. On December 12, 2024, in the middle of the night, Mr. Paragh left the residence and allegedly assaulted a neighbour with the handle of a screwdriver. He was arrested and charged with assault with a weapon and possession of a weapon. The charges remain outstanding before the court.
24. Following his arrest, Mr. Paragh was detained until his bail hearing, whereupon he was transferred to Ontario Shores and admitted to FCRU (a general forensic unit). On February 19, 2025, a Restriction of Liberty hearing was held and the Board found that his re-admission was necessary and appropriate. Dr. Wong stated that Mr. Paragh cannot return to Karis Housing.
25. As reported in the Hospital Report, following his arrest, Mr. Paragh made threats directed towards the victim, including, “I’ll shank that guy down the street, the Jamaican man with the screwdriver, I’ll kill him!” while gesturing in a stabbing motion. On February 25, 2025, during one of his outbursts, Mr. Paragh disclosed to staff about wanting to threaten and/or harm the “man down the street” but declined to elaborate; the staff interpreted this to be referring to the victim. When asked by a Board member, Dr. Wong agreed including a “no contact clause” in the Disposition, relating to the victim of the December 2024 incident, would be reasonable.
26. Dr. Wong advised that Mr. Paragh is an elevated elopement risk. On April 9, 2025, he did not return from a pass and was later found, with the assistance of a tracking device (i.e., an Apple AirTag) on his person, at the Ajax GO Train station. When canvassed by the team, Paragh explained that he had gone to “see a friend” before getting lost on the way back to hospital.
27. Mr. Paragh experienced seizures during the reporting year. The doctor stated that Mr. Paragh’s medication was changed to better manage the seizures, which has been moderately effective. In addition, an injectable antipsychotic medication was reintroduced this reporting year to address impulse control issues related to behavioural management. The doctor confirmed that Mr. Pargh’s current medication regimen is optimized, which has reduced the frequency of behavioural incidents.
28. Dr. Wong highlighted that, given Mr. Paragh’s current privilege level of unaccompanied passes to hospital grounds and accompanied passes to the community have been going well, with the assistance of the Apple Airtag (GPS) device. The doctor also confirmed that Mr. Paragh has a good relationship with his clinical treatment team.
29. With respect to community living, despite Mr. Paragh’s current wishes, Dr. Wong advised that Mr. Paragh requires a high level of supervision and support. The doctor agreed that housing Mr. Paragh with fewer residents would help prevent overstimulation, which has led to inappropriate behaviour.
30. Dr. Wong adopted the risk assessment detailed on pages 67-71 of the Hospital Report. He highlighted that given Mr. Paragh’s intellectual deficits, a strict behavioural plan, together with environmental consistency, is crucial for reducing maladaptive behaviours. The doctor emphasized that the treatment team needs to exercise caution during a discharge to the community, ensuring that adequate support systems are in place.
31. When asked, Dr. Wong was against removing “24- hour a day supervised accommodation” from Mr. Paragh’s community living clause in his Disposition. He explained that highly supervised accommodation, with highly trained staff, is required to mitigate Mr. Paragh’s risk in the community. The doctor added that Mr. Paragh’s elevated risk of elopement is another reason that a highly supervised and supported environment is needed.
32. When asked about a plan for next year, Dr. Wong advised that finding appropriate housing to address Mr. Paragh’s specific needs is a priority. He confirmed that Mr. Paragh is currently at Alternate Level of Care (ALC) and is now ready for discharge to the appropriate setting. In this regard, the doctor stated that the team is liaising with DSO (Developmental Service Ontario) to explore appropriate housing options. Dr. Wong additionally recommended increasing Mr. Paragh's involvement in activities next year, noting that he does much better when staying active.
33. No further evidence was presented at the hearing.
Final Submissions of the Parties
34. In final submissions, the parties were asked about the addition of a “no contact” clause in the Disposition relating to the victim of the alleged December 12, 2024, assault.
35. Ms. Marshall, on behalf of the Hospital, maintained her initial recommendation to continue the current Detention Disposition. She submitted that 24/7 supervised housing is the most suitable arrangement for Mr. Paragh and expressed optimism that the hospital would facilitate his return to the community once appropriate accommodation is identified. Ms. Marshall took no position regarding the addition of a “no contact” clause in the Disposition.
36. Ms. MacDonald, on behalf of the Attorney General of Ontario, maintained her initial position. She submitted that there was no air of reality to remove the “24/7 supervised” from the community living clause in the Disposition. She stated that transferring Mr. Paragh safely back into the community would require 24/7 supervised accommodation, particularly given the December 2024 assault and Mr. Paragh’s ongoing risk for elopement. Ms. MacDonald supported a “no contact” clause in the Disposition.
37. Ms. Boissonneault, on behalf of Mr. Paragh, submitted that Mr. Paragh has seen a lot of changes this year, which have been difficult for him. She stated that Mr. Paragh has been compliant with his medication regimen and is back on antipsychotic medication, which has decreased the frequency of behavioural incidents. She pointed out that Mr. Paragh has a good relationship with his treatment team and it was encouraging that the hospital was going to increase his structured activities in the coming year. In relation to removing, the “24/7 supervised” component of the living-out clause in the Disposition, Ms. Boissonneault submitted that Mr. Paragh has been under the supervision of the Board for twelve years, and it is understandable that Mr. Paragh wants more independence and less stimulation, in his community accommodation. Finally, she submitted that Mr. Paragh did not oppose the addition of a “no contact” clause in the Disposition.
Conclusion and Disposition
38. Having considered all the evidence presented at the hearing, this Board finds that Mr. Paragh continues to pose a significant threat to the safety of the public as set out in s. 672.5401 of the Criminal Code. We make these findings based on the evidence of Dr. Wong and the evidence contained in the Hospital Report, filed as an exhibit at the hearing, notwithstanding the joint position on significant threat by the parties.
(a) Significant Threat to the Safety of the Public
39. Mr. Paragh has an intellectual disability with ongoing cognitive and adaptive functioning limitations. His assaultive index offence resulted in serious injury to a member of the public. His low tolerance and frustration level can and have led to unpredictable assaultive and/or violent behaviour. It is clear in the evidence of Dr. Wong, whose evidence we accept, Mr. Paragh requires ongoing supervision and support to manage his risk. The alleged assault in the community that led to criminal charges during the past reporting year serves to highlight the significant risk he poses to public safety. This Board unanimously finds that Mr. Paragh remains a significant threat to the safety of the public.
(b) The Community Living Condition
40. Mr. Paragh’s existing Disposition allows for community living in “24- hour- a- day supervised accommodation” approved by the person in charge. Mr. Paragh, through his counsel, submits that he wishes to live more independently and requests the removal of the requirement of “24/7 supervision” in his Disposition.
41. To his credit, Mr. Paragh has a good relationship with his treatment team. Over the past reporting year, he has adjusted well to different changes in his medication regimen, which has shown success in reducing seizure activity and poor impulse control. He has attained Alternate Level of Care in hospital and is in a position to again be discharged back to the community.
42. Mr. Paragh’s treating psychiatrist, Dr. Wong, however, is opposed to removing the “24/7 supervised” requirement from his Disposition. The doctor believes such supervision is necessary to manage the risk. This Board agrees. Mr. Paragh can be unpredictable in his behaviour, which has resulted in violence towards others. In this regard, he requires close monitoring and supervision to manage the risk. Further, he remains an elopement risk which necessitates a highly supervised environment. It is worth noting that Mr. Paragh’s attack on a neighbour this past reporting year, which charges remain outstanding, took place while he resided at Karris House, a 24/7 supervised accommodation.
43. Consequently, although Mr. Paragh may one day be moved to independent accommodation, at this point in time, his ongoing risk dictates no change to the “24/7 supervised” living out clause in his Disposition. Any lessor supervised accommodation at this juncture would be neither prudent nor appropriate to manage the risk.
(c) A “No Contact” Clause
44. This Board raised the question of whether there should be a “no contact” clause in the Disposition regarding the victim of the alleged December 2024 incident. The Hospital took no position and Mr. Paragh, through his counsel, did not oppose such a clause. Counsel for the Attorney General of Ontario supported the “no contact” clause. Given the circumstances, including the nature of the alleged assault, and the fact that since his arrest, and while in hospital, Mr. Paragh made further threats of violence towards the victim, this Board finds that such a clause is appropriate and necessary.
(d) Necessary and Appropriate Disposition
45. Consequently, this Board finds that the most appropriate and necessary Disposition is the continuation of Mr. Paragh’s existing Disposition on the same terms and conditions, with the addition of a non-contact clause regarding the victim of the alleged December 2024 incident.
46. In reaching our decision, the Board has considered the safety of the public, Mr. Paragh’s mental condition, his reintegration into society, and his other needs.
DATED this 15th day of December 2025, at the City of Toronto, in the Toronto Region.
Mr. C. Flanagan
Legal Member
Office of the Registrar
Ontario Review Board