Re: Shaka E. George
ORB File No: 5166
Hearing held on: Tuesday, March 3, 2026
Place of hearing: Centre for Addiction and Mental Health
Pursuant to: Section 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Mr. J. Goldenberg
Members: Dr. R. Sheppard
Dr. G. Nexhipi
Ms. C. Murray (via Zoom)
Mr. W. Apted
Parties Appearing:
Accused: Shaka E. George
Counsel: Ms. M. Perez
The person in charge of hospital: Counsel: Ms. M. Warner
Attorney General of Ontario: Counsel: Ms. S. Malik
REASONS FOR DISPOSITION
(Dated March 18, 2026)
On September 2, 2008, Shaka George was found not criminally responsible on account of mental disorder (“NCR”) on charges of carrying a concealed weapon, assault, failure to comply with probation order, and utter threat to cause death or bodily harm, all contrary to the Criminal Code of Canada (the “Criminal Code”).
On March 3, 2026, a panel of the Ontario Review Board (“Board” or “panel”) convened to review Mr. George’s current Disposition pursuant to s. 672.81(1) of the Criminal Code. At the time of the hearing, Mr. George was ordered detained at the General Forensic unit of the Centre for Addiction and Mental Health, Toronto (“CAMH” or “the hospital”), with privileges up to and including living in the community of the Greater Toronto Area in 24 hour a day supervised accommodation approved by the person in charge.
Mr. George was present for his hearing. He was represented by counsel, Ms. M. Perez, throughout the proceedings.
A Hospital Report dated February 9, 2026, was entered as Exhibit 1. A one-page document signed by Mr. George was entered as Exhibit 2 when presented by Mr. George later in the hearing.
The issues to be determined are whether Mr. George continues to represent a significant threat to the safety of the public, 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.
For the reasons set out below, the Board finds that Mr. George continues to represent a significant threat to the safety of the public. The Board finds that a Detention Disposition at the General Forensic unit of CAMH is the necessary and appropriate Order having regard to the safety of the public, which is the paramount concern, and also having regard to Mr. George’s mental health, reintegration into society, and his other needs.
At the commencement of the hearing the parties were canvassed for their without prejudice positions. Ms. Warner, on behalf of the hospital, took the position that Mr. George continues to represent a significant threat to the safety of the public and the necessary and appropriate Disposition is a continuation of the current Detention Disposition on the same terms as last year. Counsel for the Attorney General, Ms. Malik, supported the position of the hospital.
In her initial position, Counsel for Mr. George, Ms. Perez, submitted that Mr. George no longer represents a significant threat to the safety of the public and should be granted an Absolute Discharge. She submitted that if the Board finds that Mr. George meets the threshold for significant threat, the Board should then consider a Conditional Discharge.
The Hospital Report sets out the details of the index offences, which are extracted as follows:
“Utter Death Threat
On Wednesday January 30th, 2008, the accused, Mr. George, was in a Coffee Time donut shop. After attempting to use the ATM, without a card, he asked the employee for a free donut, which was not given to him. Mr. George left the donut shop for a short time, and then returned. He slammed a ‘toonie’ onto the counter, and asked for a corn muffin. While the employee was putting the money into the cash register, he noticed that Mr. George kept looking into the cash drawer, which made him nervous. He performed the transaction quickly, and gave Mr. George his change. Mr. George then asked for a cookie as well, and was informed that he did not have enough money. Mr. George said that he wanted a drink, and tried to open the drink cooler, which had been previously locked. The employee obtained a drink for Mr. George, who paid again with a ‘toonie’. When he was giving Mr. George the change, he said that he no longer wanted the drink, and asked for his money back. The accused then began yelling at the employee, calling him derogatory names. He was told to leave the store, or the police would be called. The accused stated that if the police were called, he would kill the employee. Mr. George then threw the muffin behind the counter. Mr. George stated twice more: “Mother fucker. I’ll kill you if you call the cops.” Mr. George left the donut shop and then the employee called the police and told them the direction Mr. George had gone. The Supplementary Record of Arrest states: “The original police radio call made reference to an armed robbery that had just occurred. Officers attended the vicinity of the Coffee Time donut shop… As a result of how the radio call was received by the officers, the accused was arrested at gunpoint.”
Fail to Comply
Mr. George was on probation for a period of two years. The start date was July 12, 2006. One of the conditions of the probation order was to “Obey a curfew be in your place of residence between the hours of 10pm to 6am unless permission is obtained in writing from the probation officer.”
The Supplementary Record of Arrest indicates that “On Monday, February 4th, 2008, at approximately 1:56 am the accused was investigated at the McDonald’s restaurant located at Spadina Ave. and Queen Street West, Toronto.”
He told the officers that he had written permission from his probation officer, but that this letter was at the shelter where he was staying. He was unable to produce the letter, and the arrest was effected.
Possession of a Prohibited Weapon
On February 17, 2008, Mr. George was in the Toronto Transit Commission Terminal on 16 Wellesley St in Toronto. He was causing a disturbance by yelling loudly at no one in particular. Despite being cautioned, he continued this behaviour. The special constables were familiar with the accused, as he had behaved in this manner in the past, but previously he would heed the cautions and discontinue the disruptive behaviour. On this occasion, after being asked to leave, after leaving he came back in, opened the main doors to the terminal, and yelled at the constables “Fuck you, you fucking faggots”. When he was placed under arrest, and advised of his rights, the special constables performed a search of his person. In his right front jeans pocket, a silver folding knife was found, the type that would open with a flick of the wrist. Mr. George was subsequently arrested by officers from the Toronto Police Service.
Assault
This account of this offence is copied from the Supplementary Record of Arrest.
“The victim in this matter… resides in the City of Toronto. The accused before the court is Shaka George who presently has no fixed abode. The accused and the victim do not know each other.
On Sunday March 23rd, 2008, the victim in this matter was standing in the lobby of the Bob Rumball Centre School for the Deaf…
While standing by the front lobby the accused before the court walked up to the victim (unknown to each other) and kissed the victim numerous times about the face and upper chest. The victim is 75 years of age. The accused then fled the scene
INJURIES: no injuries sustained by the victim.
On the 25th of March 2008, the accused before the court was arrested for another matter at the same location when the incident was discovered. The accused was arrested and charged accordingly.”
Mr. George’s current psychiatric diagnoses include Schizoaffective Disorder, Substance Use Disorder, Mild Intellectual Disability, Substance-Induced Psychotic Disorder by history, and Other Specified Personality Disorder.
The Hospital Report contains extensive information regarding Mr. George’s background and history, the entirety of which need not be repeated here in detail. However, the following particulars are noteworthy:
a. Mr. George is a 47-year-old father of one child. He immigrated to Canada from Trinidad in approximately 1988. He began formal education in Canada where he was placed in classes to deal with his limited intellectual abilities.
b. Mr. George occasionally worked cash jobs doing general labour though he never held formal employment.
c. Mr. George has an extensive psychiatric history. In the 1980’s Mr. George was assessed by the School Board at Surrey Place, the J.D. Griffin Adolescent Centre in the 1990’s, and the Centre for Addiction and Mental Health in 1999. All these assessments indicated intellectual disability in the mild to moderate level. J.D. Griffin also diagnosed him with ADHD. From 1998 to 2008, he has a history of multiple short admissions to hospital including several admissions pursuant to the Mental Health Act. The Hospital Report references admissions, prior to the index offences, characterized by an angry, hostile presentation accompanied by paranoia and delusional thoughts. Substance-induced psychosis was commonly included in the diagnoses.
d. Mr. George has admitted to historically using cannabis several times per week, if not daily. He also used crack cocaine irregularly starting in 2005. There have been multiple incidents of cannabis and alcohol use while under the jurisdiction of the ORB. He continues to routinely consume cannabis.
e. Mr. George has a history in the criminal justice system including 2 assault charges, mischief under $5000, and two charges of uttering threats in 2006. There was also a significant assault on his brother in 2003 in the context of non-compliance with his medication, an assault on a stranger who he believed had not shown respect for his girlfriend, and a sexual assault on a stranger.
f. Mr. George is capable of consenting to his psychiatric treatment.
g. Mr. George is residing at a residence operated Karis (previously known as Christian Horizons). He is followed by the CAMH Expanded Forensic Outpatient Service.
h. In July 2025, Mr. George’s most responsible physician (“MRP”) was transferred from Dr. Dupre to Dr. Owen O’Sullivan. In early February 2026, his care was transferred from Dr. O’Sullivan to Dr. Laeticia Eid because Mr. George has been historically less volatile and argumentative during routine reviews with female MRPs.
i. Medication adherence has been an issue throughout the review period. Because Mr. George likes to intermittently spend nights at his girlfriend’s residence, he has regularly missed doses of oral medication. The unpredictability of his absence from his residence makes it challenging for his housing to provide him with medication for his absence. When Mr. George misses doses, housing staff have reported an increase in agitation and irritability.
j. In April 2025, due to irritability, Mr. George’s long-acting injectable antipsychotic was changed from biweekly to every 10 days.
k. Mr. George was hospitalized in June and July 2025 due to sepsis and a variant of Guillain-Barré syndrome. His long-acting injectable antipsychotic was held at that time, and he was placed on oral antipsychotic medication. The long-acting injectable medication was reinstated subsequently with a tapering down of oral medication after his discharge.
l. Mr. George has reported regularly using cannabis this reporting period. He has not refused to provide a sample and has tested positive for cannabis on at least 8 occasions. Mr. George’s relationship with his girlfriend is a potential destabilizer. They have arguments and she uses cannabis in his presence.
m. Throughout the reporting year, Mr. George’s insight has remained limited, particularly in relation to the impact of cannabis and alcohol use on his mental illness and risk. He consistently downplayed any risk related to substances associated with substance use including relapse and reoffending.
n. In November 2025, Mr. George became convinced that housing staff had stolen or hidden his SIN card. He became increasingly agitated and verbally abusive. Police attended at his residence and gave him a formal warning.
o. On January 24, 2026, Mr. George was agitated and paranoid about housing staff, believing they interfered with his food in some way. He called police and was taken to the CAMH emergency department where he was verbally abusive and threatening to staff. He was acutely agitated, required PRN medication, and a brief period in seclusion. He tested positive for cannabis.
The Board had available to it the evidence and documents forming the Record including Exhibits, the Hospital Report, and oral evidence of Dr. Owen O’Sullivan who co-authored the Hospital Report. Exhibit 2 was read by Ms. Perez on Mr. George’s behalf, and he provided viva voce evidence.
At the hearing, Dr. O’Sullivan testified that Mr. George has regularly used cannabis and alcohol over the past year. On a positive note, he has not tested positive for cocaine, despite having cravings. Mr. George consistently maintains that cannabis does not cause a deterioration in his mental health. He frames his use as positive for his mental wellbeing and does not accept that it increases his risk of violence to others. Cannabis use exacerbates Mr. George’s residual symptoms. Cannabis use, in Mr. George’s case, can trigger florid psychosis accompanied with aggressive behaviours.
Dr. O’Sullivan testified that Mr. George has a “complex diagnostic picture”. He has a limited threshold for stress. A full relapse of his major mental illness could arise from medication non-compliance and / or using cannabis. A full relapse would likely lead to behaviours similar to those at the time of the index offence.
Dr. O’Sullivan said that Mr. George is compliant with his injectable antipsychotic. However, he is not fully compliant with his oral medication, which raises his risk of significant harm to the public. Mr. George’s missed medications coincide with times he stays overnight at his girlfriend’s residence. Mr. George refuses to disclose his girlfriend’s name or address to the treatment team or Karis. He does not advise when he will be absent from Karis for overnight visits with his girlfriend. This precludes the team and Karis from providing a package of oral medications for Mr. George to take while absent. His girlfriend is a potential destabilizer due to her own substance use. Mr. George also socializes with friends who pose a similar risk to his destabilization.
The treatment team and Karis staff have seen Mr. George become quite volatile. The outpatient team has known Mr. George for several years, which helps them to manage his challenging behaviours in the community. Karis is a 24/7 supported housing placement which is central to the management of his volatile behaviours in the community. Karis provides medication supervision, meals, positive activities, access to sports.
Dr. O’Sullivan testified that if Mr. George were to receive and Absolute Discharge, he would leave Karis to go to independent housing, decline follow up psychiatric care, stop use of medications, and increase alcohol and cannabis use. This would increase his risk of reoffending violently. A Conditional Discharge would not be appropriate because the hospital needs to be able to approve his housing, which is essential to managing his risk to the public. Further, the hospital needs to be able to recall Mr. George to hospital if there was a significant increase in his risk to the public. Absent a Detention Order, box B for admission pursuant to the Mental Health Act is not available. In the event of decompensation of his mental state, the treatment team needs to be able to affect a swift admission to hospital. Even if Mr. George met the criteria for admission for observation in the event of decompensation of his mental state, he may not meet criteria to be able to maintain him in hospital for treatment, which would be essential. Prior to an Absolute Discharge, Dr. O’Sullivan would like to see Mr. George have a prolonged period of abstinence from substances, sustained compliance with all medications, consistent engagement with the treatment team, participation in psychoeducation, and pursuit of employment.
In 2023, Mr. George lost housing when he had a long readmission to hospital. Prior to admission, he was aggressive and grabbed scissors and made threats of physical harm. His suitability to return to that housing was reviewed and the decision was made to terminate his placement. The current supports in place have been able to assist with him remaining in the community at Karis. In January 2026, Mr. George was returned to the CAMH emergency department when he tested positive for cannabis and experienced heightened behavioural issues.
There have been no recent known incidents of assaults or environmental aggression. The hospital has not had corroborating information from the girlfriend, employer, or the community in general because Mr. George will not share contact information. When the police were involved in the past year, Mr. George had called police for assistance.
This year, the frequency of the long-acting injectable antipsychotic was changed from 14 days to 10 days with Mr. George’s consent. Dr. Eid has suggested that there could be a change in the long-acting injectable to allow for the discontinuation of the oral medications. Although compliance long-acting injectable medication may provide some protection from decompensation during cannabis use, Dr. O’Sullivan highlighted that the treatment team and Karis are still observing paranoia and symptoms of his mental illness.
Mr. George provided viva voce evidence at the hearing as follows: He “smokes weed but never drinks”. Weed is the only way he can cope with stress. All staff at Karis cause him hardship by taking his food, slapping his face and not respecting his girlfriend and sister. He is working on schooling. He wants to get a job. He requested that he be able to no longer be under the jurisdiction of the ORB.
In oral submissions, the parties maintained their initial positions. Ms. Perez submitted that Mr. George has been open and honest about his substance use. Dr. Eid has put forward a harm reduction approach, which Mr. George is interested in. He has consented to medication changes this year and has been compliant with his long-acting injectable medication. In the summer of 2025 when in hospital for his physical issues, he consented to and took oral medications in place of his long-acting injectable. There is no evidence of violence in the community for years. Corroboration of non-violence from members of the community is not necessary.
Analysis and Conclusions
Significant Threat
Having heard and considered the entirety of the evidence as well as the submissions from the parties, the Board finds that Mr. George remains a significant threat to the safety of the public.
Mr. George’s risk to the public stems from his psychiatric diagnoses. When unwell, he experiences delusions, hallucinations, agitation and disorganization, which have resulted in criminal behaviour. Though Mr. George has enjoyed living in the community without readmission since 2023, his ability to do so exists within a highly supportive environment.
Mr. George has a lack of insight regarding his mental illnesses, symptoms, and factors that increase his risk of violence such as medication non-compliance and substance use. Although he is adherent with his long-acting injectable medication, he is often non-adherent with his oral medications. He refuses to advise Karis when he will not be present at his residence overnight, precluding Karis and his treatment team from providing a package of medications to take with him. It is clear that he does not have insight into the risk of relapse from medication non-adherence.
The Board accepts and relies on the criminogenic risk factors set out at page 66 of the Hospital Report including:
“Mr. George has a long-standing history of non-compliance and resistance to psychiatric treatment and services. His motivation to comply with treatment is externally driven and attributable to being under the auspices of the Review Board.”
Mr. George continues to consume cannabis claiming it helps his stress. He is not engaging in any psychoeducation that would help him develop skills to manage his stress without the use of cannabis. The Board accepts Dr. O’Sullivan’s clear evidence that cannabis use exacerbates Mr. George’s residual symptoms and can trigger florid psychosis accompanied by aggressive behaviours. It is significant that just 5 weeks prior to this hearing, Mr. George’s visit to the emergency department was in the context of escalating paranoid beliefs and acute agitation during which time he required a brief period of seclusion. It is noteworthy that he tested positive for cannabis during this period of paranoia and agitation.
Mr. George clearly intends to continue consuming cannabis. The Board accepts Dr. O’Sullivan’s evidence that Cannabis use, in Mr. George’s case specifically, can trigger florid psychosis accompanied with aggressive behaviours.
Necessary and Appropriate Disposition
In light of the Board’s finding of significant risk, it is charged with shaping a Disposition for the coming year.
To safely manage Mr. George’s risks in the community, a Detention Disposition is necessary. The Board accepts the hospital’s evidence that Mr. George exhibits challenging behaviours despite the high level of supports he receives in the community. A Conditional Discharge would not be appropriate because the hospital needs to be able to approve Mr. George’s housing, which is essential to managing his risk to the public. Further, to appropriately manage risk to the public in the event of psychiatric decompensation, the hospital needs to be able to bring Mr. George to back to hospital quickly. Such decompensation and corresponding increase in risk is foreseeable, given the paranoia and agitation that necessitated Mr. George’s emergency department visit in January 2026.
Given that Mr. George is not suitable for a Conditional Discharge this year, there clearly is no air of reality to an Absolute Discharge in the coming year.
The hospital is taking steps to help move Mr. George forward in the Forensic system and reintegrate him into the community. His care has been transferred to Dr. Eid since he has historically been less volatile during routine reviews with female MRPs. His treatment team has attempted to take steps to ensure he is able to remain compliant with oral medications. Unfortunately, it appears that Mr. George has foiled their attempts. Therefore, has been a suggestion that his long-acting injectable be changed in the future to accommodate Mr. George’s non-adherence to oral medications when he is absent from his residence.
The panel thanks Mr. George for his oral evidence and appreciates it was stressful to do so.
The Board finds that the necessary and appropriate, least onerous and least restrictive Disposition is a Detention Order with no change to the terms, as set out in our formal Disposition.
DATED this 18^th^ day of March, 2026, at the City of Toronto, in the Toronto Region.
Ms. C. Murray
Legal Member
__________________
Office of the Registrar
Ontario Review Board

