Re: Paul P. Todorov, 2026 CanLII 26870

Re: Paul P. Todorov

ORB File No: 5728

Hearing held on: Thursday, January 8, 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. Weinstein

Members: Dr. K. Hand

Dr. G. Kerry

Hon. N. Kozloff

Mr. S. Duffy

Parties Appearing:

Accused: Paul P. Todorov

Counsel: Ms. J. T. Chan

The person in charge of hospital: Counsel: Ms. S. Rosales-Zelaya

Attorney General of Ontario: Counsel: Ms. V. Culp

REASONS FOR DISPOSITION

(Dated March 24, 2026)

Introduction

1. On October 28, 2010, Mr. Paul Todorov was found not criminally responsible on account of mental disorder, on charges of fail to comply with probation order, failure to comply with condition of undertaking or recognizance, and indecent acts, all contrary to the Criminal Code of Canada (“Criminal Code”).

2. Mr. Todorov is subject to a Disposition of the Ontario Review Board (the “Board”) dated January 23, 2025, which ordered that he be detained at the Forensic Service of the Centre for Addiction and Mental Health, Toronto (“CAMH”).

3. On January 8, 2026, the Board convened a hearing at CAMH to conduct the annual review of the current Disposition.

4. Mr. Todorov was present at the hearing and was represented by his counsel, Ms. J. Chan.

5. A Hospital Report, dated December 15, 2025 (the "Hospital Report"), was entered as Exhibit 1.

6. The issues at this hearing were whether Mr. Todorov is a significant threat to public safety, as defined in s. 672.5401 of the Criminal Code, and, if so, what is the necessary and appropriate Disposition in the circumstances, bearing in mind the factors enunciated in s. 672.54 of the Criminal Code?

7. For the reasons set out below and based on the expert evidence and opinions before it, the Board concluded that Mr. Todorov continues to represent a significant threat to the safety of the public. The Board found that the necessary and appropriate Disposition in the circumstances is the continuation of the existing Detention Order.

Current Psychiatric Diagnoses

8. Pedophilic Disorder;

Exhibitionistic Disorder;

Intellectual Developmental Disorder, mild;

Possible Unspecified Schizophrenia Spectrum and Other Psychotic Disorder.

Position of the Parties

9. Counsel for the hospital and for the Attorney General were recommending no change to the existing Detention Order Disposition.

10. Counsel for Mr. Todorov advised that her client was seeking a Conditional Discharge and removal of clause 4(b), which requires that he refrain from contact or communication, direct, or indirect, with any children under the age of sixteen. Counsel for Mr. Todorov advised that, for purposes of this hearing, significant threat was not in dispute.

Index Offences

11. The circumstances giving rise to the Index Offences are extracted from last year’s Board Reasons, as follows:

“On August 27, 2010, Mr. Todorov attended at a local community centre. The playground was being enjoyed by several children who were supervised by their parents. He attended the playground area and attempted to conceal himself behind a tree. He then proceeded to insert both hands down his pants and masturbate. He continued to masturbate while he watched the children play on the playground. Parents became aware of his presence and actions, and they flagged down a passing police car. He was still on scene fiddling with his pants when police arrived, and he was placed under arrest. At the time, Mr. Todorov was subject to a court order prohibiting him from attending a playground, school, or a place where children are known to be found."

12. Mr. Todorov’s history, personal background, psychiatric background, and criminal history are outlined in the Hospital Report, and they are accurately summarized in last year’s Reasons:

“Mr. Todorov was born in Toronto, Ontario and is the oldest of two children. He has not had contact with his younger brother since 2009. Mr. Todorov lived with his parents until they passed away – mother in 2002, and father in 2003. Mr. Todorov continued to live in the family home as his father died. He does not have any other family supports in the community. Due to his developmental delay, Mr. Todorov was placed in special education classes. There were numerous assessments for behavioural and cognitive problems but no hospital admissions until he became aggressive in adulthood. Mr. Todorov reported never having had friendships and preferred to be on his own starting in childhood. He has no history of relationships or marriage.

From the ages of 17 to 21, Mr. Todorov operated an ice cream bicycle cart during the summer. In 1992, he was employed as a porter at Toronto General Hospital. From 2013 to 2015, he served as a Canteen Operator in his unit at CAMH. Following this, he took on the role of Canteen Supplier at CAMH before transitioning to community living with VITA Community Living Services in 2016.

The documented sexual history is summarized as Mr. Todorov underwent a sexual behaviours assessment conducted in 2009 wherein, he expressed no interest in children, denying any experience of sexual or physical abuse during his childhood. While hospitalized at CAMH Mr. Todorov admitted to having a sexual attraction to children and showed an interest in exhibitionism. He initially dismissed masturbation but later acknowledged that he occasionally engaged in it. After beginning treatment with leuprolide, a medication to reduce sexual drive, he reported being unable to achieve an erection, despite ongoing sexual thoughts.

A records check of Canadian Police Information Centre database revealed that Mr. Todorov's criminal history includes convictions for assault, indecent acts, exposure to persons under the age of 16, criminal harassment, failure to comply with recognizance, mischief and failure to comply with probation/recognizance, among others.

The psychiatric background information is contained in the Hospital Report, and it is extensive, beginning with the first interaction with psychiatric assessments when Mr. Todorov was 3 years old due to behavioural and cognitive problems. The most consistent diagnoses included Intellectual Developmental Disorder, Exhibitionistic Disorder, and Pedophilic Disorder. While Schizophrenia was considered, this was never clinically diagnosed until later.

Mr. Todorov was evaluated due to significant developmental delays, including encopresis (passage of feces outside of toilet-trained contexts in children) and speech difficulties. Cognitive testing indicated that he had an IQ of approximately 60, consistent with a diagnosis of Mild Intellectual Developmental Disorder. He was attending school for only one hour a day in a special classroom, displaying concrete thinking, poor fine motor skills, and limited social interaction.

In 2006, it was reported that Mr. Todorov's sexual paraphilic interests related to body odour and coprophilia (sexual arousal or pleasure from feces), along with concerns about frotteurism ((interest in rubbing, usually one’s pelvic area or penis, against a non-consenting person for sexual pleasure)). A subsequent psychiatric assessment while incarcerated indicated that he struggled to cope in the general population, displaying strange behaviour that led to his placement in segregation. At that time, he was treated with antipsychotic medication for serious mental health issues.

Mr. Todorov's initial forensic psychiatric hospitalization took place in 2007 after he exhibited aggressive behaviour at his residence. He spent several days in the hospital, where he was treated with olanzapine. In February 2009, he underwent an assessment at the Sexual Behaviors Clinic at CAMH. Later, in September 2009, he was again evaluated following an incident where he assaulted random individuals on the street and allegedly exposed himself to school-aged girls.

In January 2010, Mr. Todorov was assessed for his fitness to stand trial. The evaluating psychiatrist deemed him fit to stand trial and it was advised that he participate in a sexual offender treatment group, which he ultimately did not pursue. Following the ‘not criminally responsible’ finding in October 2010, he was detained in hospital, remaining there until he was transitioned to community living in June 2016 – VITA Community Living Services. This secure residence caters to individuals with a history of sexual offences and intellectual disabilities, providing continuous staffing and supervised medication administration. In April 2018, Mr. Todorov was readmitted to hospital for about a month after expressing intentions to harm children. An adjustment in his medication helped to alleviate these thoughts, allowing him to return to his residence. Since then, Mr. Todorov has maintained relative mental stability, avoiding any significant incidents.”

Course Since Last Disposition

13. Mr. Todorov’s course since his last Disposition is set out in detail in the Hospital Report. The following extracted paragraphs are relevant to this hearing:

“Mr. Todorov continued to reside in supportive housing at VITA in King City, Ontario and was followed by FOPS throughout this reporting period.

There was no substance use. He continued to participate in recreational programming similar to the previous reporting year. He remained compliant with his medications and his insight into his diagnoses and risk remained stagnant.

While Mr. Todorov was compliant with his medications, he frequently requested doses to be reduced or medications discontinued altogether. He stated that he would stop all his medications once he received a conditional or absolute discharge.

Mr. Todorov remained resistant to discussions with the treatment team intended to build insight into the nature of the index offences, his paraphilic diagnoses and behaviours, his offence supportive cognitions, and the associated risk.”

Evidence at the Hearing

14. The Board had available to it the evidence and documents forming the Record, the Exhibits, and oral evidence from Dr. Abigail Arnold, a PGY-6 under the supervision of Dr. Wilkie, and evidence from Mr. Todorov.

Testimony of Dr. Arnold

15. Dr. Arnold testified:

a) She co-authored the Hospital Report and adopted its contents.

b) The treatment team put a funding request for an unfunded bed through Vita, but it was not approved. They will continue to look for a permanent residence for Mr. Todorov, as his current residence is considered temporary accommodation. Mr. Todorov can stay in his current housing until a permanent residence is located.

c) The treatment team is recommending a Detention Order, as it needs to approve Mr. Todorov’s accommodation. Mr. Todorov continues to lack insight into the level of supervision and monitoring he needs for the protection of public safety. He continues to request unsupervised access to the community, and the removal from his current Disposition of clause 4(b), which prohibits contact or communication, direct or indirect, with children under the age of sixteen. Granting either of these requests would cause serious concerns about the safety of the public.

d) If Mr. Todorov were to experience decompensation of his mental state, the Mental Health Act (“MHA”) would not be sufficient to bring him into hospital quickly enough to manage his risk to public safety. Mr. Todorov is capable to consent to treatment, so the Box B criteria under the MHA would not be available to the treatment team.

e) Should Mr. Todorov be on a Conditional Discharge, he would return to playgrounds, or other community centres children frequent, as he has done in the past.

f) Mr. Todorov continues to have limited insight into his history with respect to his pedophilic, and exhibitionist, disorders. Accordingly, he would not recognize any signs of his own decompensation.

g) Mr. Todorov continues to request that the treatment team reduce his dose of medications or stop those medications altogether. If Mr. Todorov were granted a Conditional Discharge, he would not return voluntarily to the hospital if requested to do so. This opinion is supported by his previous reluctance to go to a hospital, even for treatment of a very serious physical illness, pericardial effusion, despite encouragement from the team. In the event of decompensation of his mental state, he would be unlikely to recognize his deterioration, and need for treatment, and would neither return to hospital nor be willing to stay there.

h) Mr. Todorov’s goal to live independently, with unsupervised access to the community, is unrealistic.

16. In response to questions from counsel for the Attorney General, Dr. Arnold testified:

a) Mr. Todorov’s request to have the no-contact provisions removed from his current Disposition is an example of his lack of insight.

b) When Mr. Todorov experiences physical health challenges, both his mental state, and his insight, worsen. He has chronic health issues, including diabetes and hip pain, as well as a heart condition. These physical problems need to be monitored closely, so that they do not cause decompensation in his mental state. Mr. Todorov does not recall that increased physical activity is not recommended for him, as it leads to pain and changes in his mental status.

c) While Mr. Todorov is happy to stay where he is, he has repeatedly voiced his desire to live independently in the community. However, he would not receive the level of support that he currently has, which is necessary for the safety of the public.

17. In response to questions from counsel for Mr. Todorov, Dr. Arnold testified:

a) Mr. Todorov has been under the auspices of the Board and has not lived independently for over 15 years. Therefore, it is not realistic to think that he could live independently without becoming a risk to public safety.

b) There are no cures per se for Mr. Todorov’s diagnosed pedophilic, and exhibitionistic, disorders. His current medication regimen is the most effective treatment for his aberrant sex drive. Mr. Todorov continues to express a desire to decrease those medications or to stop them altogether, which he would do if he were to get either an Absolute, or even a Conditional, Discharge.

c) Mr. Todorov’s diagnosis of Intellectual Developmental Disorder is static, and it will not improve.

d) As set out in the Hospital Report, Mr. Todorov’s insight into his diagnoses have remained limited. Mr. Todorov has recently declined to engage in any treatment and particularly treatment that specifically targets sexual disorder.

e) Mr. Todorov was quite argumentative, and resistant to any conversations regarding his diagnoses of pedophilic disorder or exhibitionistic disorder. His intellectual disorder and his as very rigid thinking both contribute to his lack of insight.

f) The treatment team does not rely on Mr. Torodov’s self report in arriving at appropriate diagnoses. His claim that he originally lied about liking children is just one example of the unreliability of his self reporting.

g) It is not realistic for the hospital to recommend a Conditional Discharge, as Mr. Todorov needs 24/7 supervised housing. His concept of a Conditional Discharge is as follows: he could continue to live at his current residence; they would provide chauffeuring for him; he would be allowed to have contact with children under the age of 16; and he could attend any playground, school or community centre on his own. This concept is unrealistic for the safety of the public.

18. In response to questions from the panel, Dr. Arnold testified:

a) The recommendation of the treatment team was unanimous.

b) Mr. Todorov is currently on two sex-drive reducing medications, and he is competent to make treatment decisions.

c) Given the nature of the Index Offences, and his diagnoses, the MHA would not be sufficient to protect public safety, even with a consent-to-treatment clause, as the MHA is more reactive than proactive. Mr. Todorov’s diagnosis includes sexual exhibitionism, his criminal behaviour would occur spontaneously and without any signs of decompensation. The nature of Mr. Todorov’s illnesses, and the type of offences he could commit, require the hospital to be able to return him to hospital rapidly, should he breach his conditions.

d) It is unrealistic to craft any type of conditions for Mr. Todorov that would protect the safety of the public under a Conditional Discharge Disposition.

Testimony of Mr. Todorov

19. Mr. Todorov testified as follows:

a) As he lied to the psychiatrist about liking “kids,” they have no proof that he is a pedophile.

b) If he were to lose his Vita housing, he would become unhoused and would go to Seaton House, which is a homeless shelter.

20. No other evidence was called.

Analysis and Conclusions

21. Having heard and considered the entirety of the evidence, as well as the submissions of the parties, the Board finds that Mr. Todorov remains a significant threat to the safety of the public.

22. In Winko, the Supreme Court outlined that, in coming to the conclusion on the issue of significant risk, a Review Board should closely examine a range of evidence, including: the circumstances of the original offence; the past and expected course of the accused’s treatment; the present state of the NCR accused’s medical condition; the NCR accused’s own plans for the future; the support existing for the NCR accused in the community; and most importantly, the recommendations provided by experts who examined the NCR accused. In coming to our conclusion in this matter, the Board relies on the uncontroverted expert evidence of Dr. Arnold, in addition to the documentary evidence before us.

23. Mr. Todorov has indicated that he would stop all his medications once he received a Conditional, or Absolute, Discharge, which would greatly increase his risk to public safety.

24. Mr. Todorov remains resistant to discussions with the treatment team that are necessary to build his insight into the nature, and causes, of his Index Offences, as well as his pedophilic diagnosis.

25. The Hospital Report indicates that Mr. Todorov received a raw score of 8 on the Revised STATIC-99R. This score places him in the highest risk category, in the “Well Above Average Risk” group.

26. According to Mr. Todorov’s HCR-20 Version 3, he continues to have problems with insight. In particular, he continues to request the removal of the clause prohibiting interactions with children and unsupervised access to places where they play.

27. In particular, the Board relies on the following paragraphs from the Hospital Report:

“Factors that aggravate his risk include lack of external supervision and unsupervised and unrestricted access to the community (such as the ability to attend parks or the mall independently), lack of psychiatric treatment (such as medication and psychotherapeutic programming), and disengagement from programming geared towards coping skills and stress management.

Composite Assessment of Risk and Reoffence Scenario

Mr. Todorov’s criminogenic risk factors remain the same as the past reporting period. Specifically, poor insight, poor coping skills, history of paraphilic disorders, history of non-adherence with treatment and supervision, and negative attitudes remain of concern.

With respect to risk management, the variables that remain salient in Mr. Todorov’s case include his history of pedophilic and exhibitionistic disorders in addition to his mild intellectual developmental disorder. Historically, he also lacked insight into his diagnosis with respect to his mental health and sexual behaviours, the need for treatment, and the role that his diagnosis and lack of treatment played at the time of the index offences. He expressed a desire to reduce his prescribed medications and suggested that he would be non-adherent, if he were not under the auspices of the ORB. Similarly, without the external supervision and monitoring of the ORB, he made statements that he would engage in sexual activity with, befriend and violently assault children in the past. He also acknowledged that being under the auspices of the ORB prevented him from engaging in sexually inappropriate behaviours towards children.

This reporting period, Mr. Todorov continued to exhibit a lack of insight into his mental health diagnosis and his need for medication.

If Mr. Todorov were to re-offend, this would likely occur in the context of decreased supervision and monitoring in addition to non-adherence to psychiatric treatment. With decreased supervision, he may engage in inappropriate sexual behaviour and may omit this information when being assessed by professional supports. In this setting, housing and/or care team staff may not be available or aware of his behaviour on a day-to-day basis. He may seek out environments that place him at greater risk of reoffence such as parks or schools and in these settings, may expose his genitals and/or masturbate in front of children amongst other members of the public. If there were an opportunity to be alone with children, there may be a possibility that he would engage in inappropriate sexual or physically assaultive behaviour towards children. If unnoticed, he may return to the same location to repeat the aforenoted behaviours and would likely withhold this information from his professional supports.”

28. In light of the Board's finding of significant threat, it is charged with shaping a Disposition for the coming year.

29. The Hospital Report accurately summarizes why a Conditional Discharge is inappropriate, particularly the need to retain the authority to approve Mr. Todorov’s accommodation. We note that his current Disposition, and the hospital’s recommendation, require that he live in 24-hour supervised accommodation. The Board agrees that this level of supervision is necessary to protect the safety of the public. In particular, the Board relies on the following extracted paragraphs from the Hospital Report:

“Under the auspices of the ORB on a conditional discharge (Mr. Todorov’s request), all Risk Management items would be elevated to present and highly relevant including problems with professional services and plans, living situation, personal support, treatment or supervision response, and stress or coping. He would likely discontinue his prescribed medications including leuprolide and medroxyprogesterone as he has voiced a plan to do so in these circumstances. He may not continue to reside in 24-hour supervised accommodations as in the past he has voiced a desire to live independently in a private apartment. In the context of decreased supervision, he would likely attend environments where children are present and would likely not be forthcoming with the treatment team when canvassed about his whereabouts. As he continues to develop coping skills, it may be difficult for Mr. Todorov to implement these skills in circumstances where there is high stress and limited staff support. Taken in totality, these circumstances would likely place Mr. Todorov at an elevated risk to reoffend violently and/or sexually.”

30. The evidence before us is quite clear that the hospital requires the ability to readmit Mr. Todorov expeditiously, in the context of a change in his dynamic risk, given his poor insight and historical problems with treatment supervision. The MHA alone would not be sufficient for this purpose, as it is more reactive than proactive. In the past, Mr. Todorov committed offences before any indication of decompensation in his mental state. Therefore, it is likely that future offences would happen quickly and without warning.

31. The Board has no doubt that Mr. Todorov’s housing staff play a central role in his supervision and monitoring while living in the community, which is necessary to protect the safety of the public.

32. In consideration of all the evidence, submissions of the parties and criteria set forth in s. 672.54, the paramount consideration being the safety of the public, in addition to the mental condition of Mr. Todorov, his reintegration into society and his other needs, the necessary and appropriate Disposition is to continue with a Detention Order.

DATED this 24^th^ day of March, 2026, at the City of Toronto, in the Region of Toronto.

Mr. J. Weinstein

Alternate Chairperson

__________________

Office of the Registrar

Ontario Review Board