Ontario Review Board
Re: Wadea Al-Lala
ORB File No: 8471
Hearing Held On: Thursday, March 26, 2026
Place of Hearing: Centre for Addiction and Mental Health
Pursuant To: Section 672.81(1) of the Criminal Code
Before:
Alternate Chairperson: Ms. L. Banks
Members: Dr. S. Lessard
Dr. J. Cheston
Ms. A. La Viola
Mr. J. Cyr
Parties Appearing:
Accused: Wadea Al-Lala
Counsel: Ms. M. Perez
The person in charge of hospital: Counsel: Ms. M. Warner
Attorney General of Ontario: Counsel: Ms. N. Engineer
REASONS FOR DISPOSITION
(Dated May 12, 2026)
OVERVIEW
- Wadea Al-Lala was found not criminally responsible on account of mental disorder on January 19, 2024, for the offence of second-degree murder, contrary to the Criminal Code. He is currently subject to a disposition of the Ontario Review Board dated March 27, 2025, detaining him at the Forensic Service of the Centre for Addiction and Mental Health, Toronto (“CAMH”). The disposition includes privileges, including the ability to enter the community of the Greater Toronto Area, indirectly supervised.
ISSUES
On March 26, 2026, the Board convened at CAMH for a hearing further to s. 672.81(1) of the Criminal Code to review the disposition. The Board was asked to determine whether Mr. Al-Lala represented a significant threat to the safety of the public at the time of the hearing, and further, what the necessary and appropriate disposition is in the circumstances according to the factors set out in s. 672.54 of the Criminal Code.
At the outset of the hearing, the parties made a joint recommendation to the Board and submitted that Mr. Al-Lala continues to represent a significant threat to the safety of the public, and that the necessary and appropriate disposition is a continuation of the current detention order, with the addition of community living clause with weekly reporting requirements. In addition, Counsel for Mr. Al-Lala requested travel passes within Southern Ontario, with an approved person, and subject to an itinerary approved in advance by the person in charge of the hospital.
FINDINGS
- After hearing the evidence, the Board found that Mr. Al-Lala continues to pose a significant threat to public safety and that the existing detention order remains the least onerous and least restrictive disposition capable of managing risk, protecting public safety, and supporting continued rehabilitation, with the addition of community living privilege in accommodation approved by the person in charge of the hospital, a weekly reporting requirement and travel provisions within southern Ontario, with an approved person, and subject to an itinerary approved in advance by the person in charge of the hospital, all as set forth in his formal disposition.
BACKGROUND
The Hospital Report dated March 4, 2026, was entered as an exhibit at the hearing. Also admitted into evidence were two victim impact statements that had been filed with the Board. The victim impact statements were admitted subject to a ruling made that the Board would consider only the contents of the victim impact statements that complied with s. 672.5(14) of the Criminal Code, namely “a written statement describing the harm done to, or loss suffered by, the victim arising from the commission of the offence”.
The following information, including the events surrounding the index offence, has been taken from the Hospital Report, summarized here as follows. On November 22, 2020, Mr. Al‑Lala met the victim at her Toronto apartment, where she had previously been assisting him with immigration matters. Shortly after arriving, he attacked her with a knife, inflicting multiple stab wounds inside the apartment and into the hallway. Neighbours heard her screams, witnessed parts of the assault, and attempted to intervene, including one neighbour who struck Mr. Al‑Lala with a baseball bat. Despite this, the assault continued until the victim sustained fatal injuries. Mr. Al‑Lala then fled the building, attempted to enter a passing vehicle, and was detained by police minutes later, bleeding from lacerations to his hands.
Mr. Al-Lala is 26 years old, and he was born in Jordan. He spent most of his childhood in Riyadh, Saudi Arabia, where his father worked and the family resided until immigrating to Canada beginning in 2017. He completed high school in Saudi Arabia, describing himself as a strong student with no behavioural issues or learning difficulties. He came to Canada at age 17 to study English at the University of PEI before relocating to Toronto.
Prior to the index offence, he lived with his parents and siblings in Scarborough and worked reliably in several positions. His substance use began in adolescence with weekend hashish use in Saudi Arabia and escalated significantly after moving to Toronto, where he used cannabis heavily, at times consuming up to 7 grams daily. He experimented with multiple substances, including cocaine, MDMA, magic mushrooms, Xanax, Percocet, fentanyl, and crystal amphetamine, though cannabis remained his primary drug. He never sought treatment for substance use.
Mr. Al‑Lala has a limited criminal history prior to the index offence. In 2019, he was convicted of uttering threats and possession of a weapon, receiving concurrent conditional sentences of approximately six months and probation for six months. The Hospital Report indicates that Mr. Al-Lala was unable to finish further schooling as he threatened to kill another student. He pleaded guild to uttering threats but reported that the threats arose from a verbal exchange with a fellow student, which he characterized as joking, though the complainant reported it to school authorities.
Mr. Al‑Lala’s first psychiatric contact occurred in April 2018 in Jordan, where he was hospitalized for a severe substance induced psychosis following heavy cannabis use and emerging grandiose and religious delusions.
After returning to Canada, he experienced recurrent psychotic symptoms associated with ongoing substance use, and records show psychiatric follow up in 2019. Prior to the index offence, he again developed paranoia, grandiosity, and perceptual disturbances in the context of polysubstance use. Following his arrest for the index offences, he displayed disorganized, religiously preoccupied behaviour and he received antipsychotic treatment while he was in custody.
Mr. Al-Lala’s current diagnoses are Substance Induced Psychosis, Schizophrenia, Opioid Use Disorder and Cannabis Use Disorder. He is currently capable of consenting to psychiatric treatment, and he is capable of managing his financial affairs.
EVIDENCE
Over the past year, Mr. Al-Lala has remained psychiatrically stable, with no symptoms of psychosis, no mood disturbance, and no behavioural concerns. His interactions with staff and co‑patients have been generally cooperative and respectful, aside from occasional glibness when making requests.
He has been fully compliant with his long-acting antipsychotic medication that he receives every three months, weekly urine drug screens have been consistently negative, and he has engaged in relapse prevention programs. He has actively participated in community-based programming, volunteer work, recreational activities, and ongoing individual counselling. His parents and siblings remain closely involved and supportive. Overall, his course has been stable, cooperative, and free of psychiatric or behavioural deterioration.
The evidence at the hearing included comprehensive testimony from Dr. P. Benassi regarding Mr. Al-Lala’s current mental health status and behaviour. Dr. Benassi has been Mr. Al-Lala’s attending in-patient psychiatrist since Mr. Al-Lala’s transfer to a general forensic unit.
Dr. Benassi stated that Mr. Al‑Lala transferred from a secure unit to a general forensic unit in April 2025. He described the transition as positive and stable, noting that throughout the past reporting year there has been no evidence of psychosis, disorganization, hallucinations, or delusional thinking. His mental state has remained consistently stable, and he has demonstrated appropriate behaviour on the unit without interpersonal conflicts, intimidation, volatility, or difficulties with staff or co‑patients. Dr. Benassi emphasized that none of the behavioural concerns Mr. Al-Lala has presented with in the past have re-emerged.
Dr. Benassi explained that Mr. Al‑Lala has progressed steadily through the privilege ladder and has been exercising the maximum permitted privileges under his current disposition since the summer of 2025. This has included increasing day passes, followed by overnight passes, as well as 48-hour and 72-hour approved person passes to his family home. These passes have been used consistently for approximately six months without incident. Random urine drug screens have returned negative for the presence of illicit substances, and there has been no evidence of substance use during indirectly supervised community access. His compliance with expectations has been reliable.
Dr. Benassi described Mr. Al‑Lala’s engagement in treatment as strong. He has completed substance use relapse prevention work with both psychology and social programs, and he has participated in rehabilitative and community‑based programming, including volunteer roles. He also noted that Mr. Al-Lala consented to transition from oral antipsychotic medication to a long-acting injectable formulation, and Mr. Al-Lala has remained adherent.
In the doctor’s view, it is critical that Mr. Al-Lala continue with treatment with his long-acting injectable medication, particularly during the first year of community reintegration, a period that Dr. Benassi described as inherently vulnerable due to increased stressors and opportunities for substance use. Even if Mr. Al-Lala’s psychosis was substance induced, the long-acting injectable medication provides a protective effect and mitigates the risk of relapse should he use substances.
Regarding insight, Dr. Benassi stated that Mr. Al‑Lala attributes the index offence to being psychotic in the context of substance use. He has not heard him blame the victim or minimize his responsibility. Dr. Benassi acknowledged that assessing empathy is inherently difficult, but he emphasized that his behaviour – engagement in treatment, abstinence, compliance with expectations, and willingness to follow recommendations – demonstrates that Mr. Al-Lala is taking responsibility and acting in ways that reduce risk. He also noted that there is no developmental or historical pattern suggestive of antisocial personality traits, rather, his past behavioural issues appear linked to psychosis and substance use.
Dr. Benassi described Mr. Al-Lala’s family as consistently supportive. They provide important emotional support, participate in treatment planning, and reinforce abstinence and medication adherence. They have reliably supervised his passes and maintained communication with the treatment team. Historically, they attempted to secure treatment for him both in Jordan and in Canada, and they continue to demonstrate insight into his vulnerabilities and the importance of ongoing treatment.
Dr. Benassi testified that the current disposition leaves little room for further progress, as Mr. Al‑Lala has already maximized all available privileges currently available under his disposition. In his view, the addition of a discretionary community living privilege is the appropriate next step to support reintegration while maintaining public safety. He also indicated that the team is not opposed to a travel provision permitting travel within Southern Ontario for up to seven days, provided that the hospital retains discretion to approve Mr. Al-Lala’s itinerary, confirm supervision, and ensure appropriate safeguards. The doctor explained that such travel passes would begin with shorter durations, expanding only if clinically appropriate.
Dr. Benassi stated that Mr. Al-Lala’s legal status in Canada is not yet resolved, and he is currently applying for permanent resident states. Until he achieves same, he will not be able to access subsidized community housing. In addition, the doctor commented that the treatment team has been evaluating the parents and their home, and that is the reason that Mr. Al-Lala has been increasingly granted passes to spend time with his parents at their family home. Dr. Benassi also indicated that no occupational assessment had yet been conducted to identify the level of support Mr. Al-Lala needs in the community.
Finally, Dr. Benassi confirmed that although the team had previously considered a trial discontinuation of antipsychotic medication, they now view this as premature in the context of community reintegration. Dr. Benassi reiterated that maintaining the injectable antipsychotic medication is important for risk mitigation during this transitional period.
SUBMISSIONS
Counsel for the hospital submitted that the evidence supports adding a community living privilege, noting this is the second year it has been recommended. Counsel did not have instructions from the person in charge of the hospital, so she took no position on the addition of the travel passes recommendation, but she did acknowledge Dr. Benassi’s evidence in support.
Counsel for the Attorney General supported a community living clause, citing Mr. Al‑Lala’s positive year, successful unit transition, and sustained safe use of privileges. She did not oppose travel within Southern Ontario with an approved person and subject to an approved itinerary by the person in charge.
Counsel for Mr. Al‑Lala supported community living, emphasizing his compliance, treatment engagement, insight, and family support. She submitted that limited travel within Southern Ontario is clinically appropriate and consistent with the evidence, and that Mr. Al‑Lala has managed increased liberties responsibly.
ANALYSIS AND CONCLUSION
(a) Significant Threat
The Board must first determine whether Mr. Al-Lala continues to pose a significant threat to the safety of the public as that term is defined in Winko v. British Columbia (Forensic Psychiatric Institute), 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625. A significant threat exists where there is a real risk of serious physical or psychological harm to members of the public, resulting from conduct that is criminal in nature, and where that risk is not merely speculative.
Having considered the totality of the evidence, including the detailed Hospital Report and the testimony of Dr. Benassi, the Board is satisfied that the statutory threshold continues to be met. Although Mr. Al‑Lala has demonstrated a sustained period of psychiatric stability, abstinence, and responsible use of privileges, the evidence establishes that his risk of serious violence would become significant in the absence of ongoing supervision, monitoring, and treatment.
The index offence was a sudden, severe, and unprovoked act of extreme violence, occurring in the context of psychosis and heavy substance use. While Mr. Al-Lala has been stable on the long-acting injectable antipsychotic medication, the treatment team emphasized that the first year of community reintegration is a period of heightened vulnerability, especially with respect to relapse into substance use as a factor that has repeatedly triggered psychosis and paranoia in the past. Mr. Al-Lala’s insight remains partial, and he continues to attribute his past psychosis primarily to substance use, expressing uncertainty about whether he would decompensate if his medication were discontinued.
The evidence also demonstrates that when unwell, Mr. Al‑Lala’s symptoms have escalated rapidly and dramatically, and his past violence has been severe, unpredictable, and difficult to interrupt, even in the face of intervention. Although his behaviour over the past year has been positive, the hospital was clear that ongoing supervision, monitoring for substance use, and adherence to antipsychotic medication remain essential to mitigate risk. Without these safeguards, the risk of serious violence would be real, not trivial. Accordingly, the Board finds that Mr. Al‑Lala continues to pose a significant threat to the safety of the public.
(b) Necessary and Appropriate
The Board must next determine the disposition that is necessary and appropriate in the circumstances. The disposition must reflect the principle of the least onerous and least restrictive alternative that protects the public, while giving due consideration to Mr. Al-Lala’s mental condition, his reintegration into society, and his other needs as required by s. 672.54 of the Criminal Code.
The Board accepts that Mr. Al‑Lala has made meaningful and sustained progress over the past reporting year. He has remained psychiatrically stable, abstinent from substances, and fully compliant with treatment. He has successfully exercised the maximum privileges available under his current order, including weekly 72-hour approved person passes to his family home, all without incident. He has engaged in community-based programming, volunteer work, and relapse prevention counselling, and he has maintained strong family support.
The Board is satisfied that adding a discretionary community living privilege – along with the appropriate safeguards – is the least restrictive means of supporting Mr. Al-Lala’s continued reintegration into society while maintaining public safety. The Board also accepts that a travel provision within Southern Ontario, for up to seven days with an approved person, and subject to pre‑approval of the itinerary, can be safely managed.
Nonetheless, given the ongoing need for structured monitoring, medication adherence, and oversight during this early phase of community reintegration, the Board finds that a detention order remains necessary and appropriate because the evidence also establishes that significant risk factors remain. Notably, Mr. Al-Lala remains dependent on intensive supervision, and enforced treatment compliance. It is important that the hospital retain the authority to approve his placement in the community when he is ready for the transition. In addition, the hospital requires the means to rapidly readmit Mr. Al-Lala under a warrant of committal should Mr. Al-Lala relapse into substance use or should a decompensation of his mental state occur. Further, the Mental Health Act would be insufficient to ensure timely intervention should Mr. Al La-la decompensate while living in the community, and a conditional discharge would not provide an adequate framework to manage the ongoing risk to public safety in the circumstances.
DATED this 12^th^ day of May, 2026, at the City of Toronto, in the Toronto Region.
Ms. A. La Viola
Legal Member
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Office of the Registrar
Ontario Review Board