Re: Pertti Tulikorpi, 2026 CanLII 39752

Ontario Review Board

Re: Pertti Tulikorpi

ORB File No: 1300

Hearing held on: Wednesday, April 8, 2026

Place of hearing: Ontario Shores Centre for Mental Health Sciences 700 Gordon Street, Whitby

Pursuant to: Section 672.81(1) of the Criminal Code

Before:

Alternate Chairperson: Mr. J. Weinstein

Members: Dr. K. Hand Dr. M. Kalia Hon. A. Sosna Mr. J. Cyr

Parties Appearing:

Accused: Pertti Tulikorpi Counsel: Ms. J. Boissonneault

The person in charge of hospital: Representative: Dr. K. De Freitas

Attorney General of Ontario: Counsel: Ms. N. MacDonald

REASONS FOR DISPOSITION

(Dated April 30, 2026)

Introduction

1. On April 30, 1991, Mr. Pertti Tulikorpi was found not guilty by reason of insanity, on a charge of assault with a weapon, contrary to the Criminal Code of Canada (“Criminal Code”). Mr. Tulikorpi is subject to a Disposition of the Ontario Review Board (the “Board”), dated May 5, 2025, which ordered that he be detained at the Forensic Program at Ontario Shores Centre for Mental Health Sciences (“Ontario Shores”).

2. On April 8, 2026, the Board convened a hearing at Ontario Shores to conduct the annual review of the current Disposition.

3. Mr. Tulikorpi was represented by his counsel, Ms. J. Boissonneault, who advised that her client did not wish to attend this hearing and that she had instructions to proceed in his absence. An order was made, pursuant to s. 672.5(10)(a), allowing Mr. Tulikorpi to be absent from this hearing.

4. A Hospital Report, dated March 10, 2026 (the “Hospital Report”), was entered as Exhibit 1.

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

6. For the reasons set out below and based on the expert evidence and opinions before us, the Board concluded that Mr. Tulikorpi 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 a continuation of the existing Detention Order.

Current Psychiatric Diagnoses

7. Schizophrenia

Unspecified Personality Disorder

Psychogenic Polydipsia

Position of the Parties

8. Dr. De Freitas, as representative of the hospital and as the most responsible physician, counsel for the Attorney General, and counsel for Mr. Tulikorpi advised that this was a joint submission. All were adopting the hospital’s recommendation of a continuation of the existing Detention Order.

9. For the purposes of this hearing, counsel for Mr. Tulikorpi advised that significant threat was not in dispute.

Index Offence

10. The circumstance giving rise to the Index Offence are extracted from last year's Board Reasons, as follows:

“According to the March 2010 MHCP Administrator’s Report to the Ontario Review Board, at the time of the offence, Mr. Tulikorpi was residing in a rooming house for mentally ill consumers. In February 1991, he had become increasingly paranoid. On March 11, 1991, he took a knife from the kitchen and stabbed a male night staff person who he believed was sending him messages indicating he was about to strangle the patient's mother. He also believed the victim had repeatedly raped and beaten him. Mr. Tulikorpi ran from the building and was apprehended by the police. Reportedly, the victim required hospitalization for his injuries.”

Criminal Record

11. Mr. Tulikorpi’s criminal record prior to the index offence is as follows:

DATE AND LOCATION

CHARGE(S)

SENTENCE

1981-11-17 Toronto, ON

Mischief

Conditional Disch & 2 years’ probation

1982-08-03 Whitby, ON

Failure to Appear Breach of Probation

(1-2) $100 I-D 10 days & 18 months’ probation on each charge

1982-12-08 Toronto, ON

Breach of Probation Public Mischief

(1-2) Suspended sentence & 1 year probation

1987-10-29 Toronto, ON

Sexual Assault

Suspended sentence & 3 years’ probation

1988-06-01 Toronto, ON

Theft Under $1000 Failure to Appear

(1-2) Suspended sentence

1990-06-26 Toronto, ON

Theft Under $1000 Failure to Appear

$200 I-D 20 days $100 I-D 10 days consec

According to Mr. Tulikorpi’s CPIC, he was charged with Break and Enter, Theft, Possession of Stolen Property Under $200, and Breach of Probation, all of which were withdrawn.

Personal History and Background

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

“It is of note that Mr. Tulikorpi has resided in a mental health hospital since being found not guilty by reason of insanity in 1991. He was born in Toronto but returned with his family to reside in Finland shortly after his birth. When he was eight years old his family moved back to Canada. When he was 12 years old his parents separated. He has two older brothers. After his parents’ separation Mr. Tulikorpi began neglecting his schoolwork and using street drugs. This resulted in his expulsion from school. At the age of 20 he returned to Finland to live with his mother. While in Finland, he began to display paranoid and aggressive behaviour resulting in assessment at a mental hospital. He was not admitted but returned to Canada to live with his father, who was a retired RCMP officer. When not living with his father he maintained a transient lifestyle in Toronto, residing at various shelters and rooming houses, reportedly causing problems in all of them. The Hospital Report contains details of his admissions to a number of different hospitals following a decline in his mental status. In October 1986, he was discharged from Wellesley Hospital in Toronto with a diagnosis of chronic schizophrenia.”

Course Since Last Disposition

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

“Following Mr. Tulikorpi’s last Review Board hearing, he remained on the secure Forensic Assessment Rehabilitation Unit (FARU) until his transfer to the secure Forensic Rehabilitation Unit (FRU). While an inpatient on FARU, Mr. Tulikorpi frequently presented with symptoms consistent with water intoxication; including loud vocalizations, persecutory delusions, increased frequency of clothing changes, and a blue hue to his lips.

Mr. Tulikorpi was transferred to the FRU on October 22, 2025. Following transfer, he remained cooperative with his care plan regarding pre-meal urine specific gravity screenings. However, he continued to demonstrate limited insight into the physiological risks associated with low urine specific gravity and water intoxication. Mr. Tulikorpi continued to exhibit persistent compulsive water-seeking behaviours; frequently using washroom taps for water ingestion. This behaviour required frequent staff redirection and nursing interventions.

Over this reporting period Mr. Tulikorpi has had three incidents of water intoxication that required the treatment team to utilize the Quiet room. During these incidents of water intoxication Mr. Tulikorpi became verbally aggressive and verbally threatened staff

Mr. Tulikorpi had two incidents of physical aggression. The first incident involved Mr. Tulikorpi attempting to hit a member of the treatment team with a closed fist.

The second incident involved Mr. Tulikorpi kicking another patient in the shin. Mr. Tulikorpi felt that this patient was bothering him. Mr. Tulikorpi had limited insight into his behaviour.”

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. De Freitas.

15. Dr. De Freitas is Mr. Tulikopi’s treating psychiatrist, she co-authored the Hospital Report and testified as follows:

a) As the Hospital Report covers the issue of significant threat and as this issue is not in dispute, she would focus primarily on the community placement challenges the hospital faces with respect to Mr. Tulikorpi.

b) Mr. Tulikorpi is probably the most difficult person she has ever had to place in the community, because of his water intoxication issue. He cannot be left alone with water taps or any water sources. When unsupervised, he rapidly consumes excessive water, leading to a deterioration in his mental state resulting in: agitation; behaviour that is threatening or sexually inappropriate; and potential aggression. For example, he will consume a gallon of water if staff turn their backs for even a moment. Accordingly, the hospital engages in the following controls: Mr. Tulikorpi is limited to five-minute showers; there are regular searches of his room for cups and drinking vessels; and he is monitored at meals to prevent him from taking fluids from other patients.

c) This overhydration also poses a serious health risk for Mr. Tulikorpi.

d) Cannabis use is also a significant risk factor. Every time Mr. Tulikorpi has been moved to a medium security unit, he has engaged in cannabis use.

e) Mr. Tulikorpi has no insight into the risk that cannabis has on his behaviour and his risk to public safety. He has told her that he would consume cannabis if given the chance. He also has no insight into the effects of his water intoxication.

f) There are numerous placement barriers facing Mr. Tulikorpi because of the close monitoring that he needs to prevent both water intoxication and cannabis consumption. Group homes cannot provide the level of supervision he requires. In addition, any accommodation would have to provide a locked unit, to prevent Mr. Tulikorpi from wandering and consuming water.

g) The hospital is now exploring long-term care (“LTC”) facilities, as they can manage very ill individuals and generally have staff on site to provide the close supervision that Mr. Tulikorpi needs. Mr. Tulikorpi has been found incapable to consent for placement decisions. The treatment team is now contacting his current substitute decision maker (SDM) for psychotropic medication to see if they will also agree to be his SDM for placement.

h) Another complicating factor is his violent index offence .

i) Mr. Tulikorpi refused to be trialled on clozapine and will not consent to the required blood work.

j) Multiple antipsychotic medications have been trialled with limited benefits. Mr. Tulikorpi is currently on olanzapine. His psychosis is “reasonably well” controlled when his water intake is limited, and he is not using cannabis.

k) When Mr. Tulikorpi’s water and cannabis are controlled, she would describe him as polite and cooperative. There have been no aggressive incidents this past reporting period.

l) Mr. Tulikorpi has been under the Board for over 35 years. He can be described as being institutionalized. He cannot live independently.

16. In response to questions from counsel for Mr. Tulikorpi, Dr. De Freitas testified:

a) The Hospital Report indicates that Mr. Tulikorpi has been able to go out with groups, on the hospital grounds and into community. In the last month, he has gone onto hospital grounds twice and into the community four times, and those passes have generally gone well. These escorted outings have been successful when he is supervised and not water intoxicated.

b) Mr. Tulikorpi has shown improved activity engagement this reporting period versus the previous one. However, the addition of olanzapine in the last reporting period has not provided any sustained improvement.

c) Mr. Tulikorpi is very sensitive to side effects. Should the treatment team increase his doses of his current medication, they would risk him becoming non-adherent, which has been a long-standing issue. From a psychosis management perspective, Mr. Tulikorpi is doing reasonably well, and further dose escalations are unlikely to eliminate his delusions.

d) The hospital would have no issue transferring Mr. Tulikorpi directly from the medium secure Forensic Rehabilitation Unit (FRU) to a long-term care ( LTC) facility, and this transfer is the only viable path forward.

17. In response to questions from the panel, Dr. De Freitas testified:

a) Mr. Tulikorpi’s stated goals of where he wants to live – in a group home or independently – fluctuates, depending on when he is asked.

b) Mr. Tulikorpi did regress in the previous reporting period (2024-2025), with several incidents of aggression, such as grabbing staff, swinging at them, and kicking a patient. They are no longer seeing these behaviours, and he has returned to his long-term baseline.

18. No other evidence was called.

Analysis and Conclusions

19. Having heard and considered the entirety of the evidence as well as the submissions from the parties, the Board agrees with the joint submission: Mr. Tulikorpi remains a significant threat to the safety of the public.

20. 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. De Freitas, in addition to the documentary evidence before us.

21. Mr. Tulikorpi was involved in two incidences of physical aggression this reporting period. The first involved him hitting a member of the treatment team with a closed fist; the second involved him kicking another patient in the shin. Mr. Tulikorpi has limited insight into his behaviours and his risk.

22. Mr. Tulikorpi continues to reside in a Secure Forensic Unit. Mr. Tulikorpi has expressed that he does not wish to reside on a General Forensic Unit or in a group home.

23. Mr. Tulikorpi’s supervised community passes have gone well, showing some functional stability under structured conditions. He has shown some progress in his level of physical activity and social engagement during this period. Mr. Tulikorpi successfully participated in staff-escorted indoor group walks.

24. Mr. Tulikorpi’s behaviour is stable and cooperative when water intake and cannabis use are controlled. It is quite clear that Mr. Tulikorpi cannot be left alone with water taps or water sources. If unsupervised, he rapidly consumes excessive water, leading to a deterioration in his mental state and threatening, and sexually inappropriate, behaviour.

25. The treatment team is currently working with what the doctor referred to in her evidence as the Community Care Access Centre (“CCAC”), which is now known as Ontario Health atHome. They are looking for an appropriate long-term care facility that can provide locked units, as well as very close supervision, to ensure that Mr. Tulikorpi does not engage in excessive water consumption or cannabis use.

26. In particular, the Board relies on the Clinical Assessment of Risk from the Hospital Report:

“It is the unanimous opinion of the treatment team that Mr. Tulikorpi remains a significant threat to the safety of the public. The most significant risk factor remains his major mental illness, namely treatment resistant schizophrenia. He continues to have active psychotic symptoms, including persecutory delusions, intermittent agitation, and psychogenic polydipsia, despite treatment with multiple antipsychotic medications. He has very poor insight into his psychotic illness, need for treatment, and need to refrain from excessive water consumption. He has refused clozapine treatment, the gold standard for treatment resistant schizophrenia.

Even when compliant with antipsychotic treatment, he has engaged in physically aggressive behavior in the past reporting period. Without the support and supervision of the Secure forensic unit, it is likely that he would discontinue his antipsychotic medication and experience an exacerbation of his psychosis, which would manifest as increased paranoia and agitation, and eventually lead to physical aggression. It is also likely that his psychogenic polydipsia would worsen, and the resulting water intoxication would lead to increased disinhibition and increased likelihood of physical aggression. He also remains at risk of sexually inappropriate behaviors.

There is also a risk that, absent the supervision of the Secure forensic unit, he would revert to illicit substance use, which would further exacerbate his psychosis, and increase his risk to the public.”

27. 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. Tulikorpi, his reintegration into society and his other needs, the necessary and appropriate Disposition is to continue with the Detention Order.

DATED this 30^th^ day of April 2026, at the City of Toronto, in the Region of Toronto.

Mr. J. Weinstein Alternate Chairperson Office of the Registrar Ontario Review Board