Re: Colin Sookram, 2026 CanLII 53932

Re: Colin Sookram

ORB File No: 8148

Hearing held on: February 17, 2026

Place of hearing: St. Joseph's Healthcare Hamilton West 5th Campus, 100 West 5th Street

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

Before: Alternate Chairperson: Ms. K.A. Connidis Members: Dr. J. Cheston Dr. S. Bouskill Mr. D. D’Intino Ms. B. Little

Parties Appearing: Accused: Colin Sookram Counsel: Mr. M. Schloss The Person in Charge of Hospital: Counsel: Ms. L. Barney Attorney General of Ontario: Counsel: Mr. I. Shaikh

AMENDED REASONS FOR DISPOSITION (Dated June 2, 2026)

Please see the underlined changes made on June 4, 2026, to the original reasons on pages 6, 9, and 13.

Introduction

1. On August 31, 2022, Colin Sookram was found not criminally responsible on account of mental disorder (NCRMD), on a charge of manslaughter, contrary to the Criminal Code of Canada (“Criminal Code”).

2. Mr. Sookram is subject to a Disposition of the Ontario Review Board (the “Board”), dated March 3, 2025, and amended April 8th, 2025, which orders that he be detained at St. Joseph’s Healthcare Hamilton (SJHH) with privileges up to and including residing in the community of Southern Ontario in accommodation approved of by the Person in Charge.

3. On February 17, 2026, a panel of the Ontario Review Board (ORB) convened in person and a hearing was held at SJHH. The purpose of the hearing was to determine if Mr. Sookram continues to represent a significant threat to the safety of the public as defined in the Criminal Code of Canada, and if so, what is the necessary and appropriate Disposition for him for the year ahead.

4. For the reasons set out below, the Board unanimously finds that Mr. Sookram continues to represent a significant threat to the safety of the public, and that the necessary and appropriate Disposition is a continuation of his current Detention Order Disposition with no changes to its terms and conditions.

Current Psychiatric Diagnoses:

• Schizophrenia;
• Cannabis Use Disorder, currently in sustained remission, in a controlled environment;

Index Offence:

5. The facts arising from the index offence are set out in the Hospital Report (at pages 2-3):

“At the time of his death [Victim name redacted] was a 46-year-old-man. He was murdered at the residence where he rented a room at [address redacted] in Brampton. He was stabbed multiple times by Mr. Sookram on or about April 7, 2018. John Lopez witnessed what happened.

The events that led to the murder during the early morning hours of Saturday April 7th when John Lopez attended at the Pro Sports Bar at 630 Peter Robertson Blvd, Brampton. Lopez was observed to be acting in an erratic manner. He was dancing wildly and playing with his clothing. When Lopez was involved in the altercation inside the bar, he was asked to leave by the bar owner.

Once outside the bar, Lopez got into a fight with one or more of the patrons. Eventually the fight deescalated leaving Lopez and the others to go their separate ways.

As Lopez was walking away his attention was drawn to Sookram who was driving a vehicle nearby. Sookram offered to drive Lopez away from the bar. Although both parties were unknown to each other, Lopez accepted the offer and got into the passenger seat.

Lopez directed Sookram to drive to [address redacted] in Brampton. The owner of the premises was a young man named Cody Nolter-Wilkes. Lopez was a friend to Cody and was hoping that Cody could supply him with marijuana.

When Lopez and Sookram arrived at [address redacted] they entered through the backyard gate and back sliding door. Cody was not home. However, they found [Victim] sitting on a couch in the living room in front of the television. [Victim] was renting a room in the house.

Lopez, Sookram and [Victim] smoked some hash. When it was time for Lopez and Sookram to leave they made their way to the back sliding door, but Sookram unexpectedly moved towards [Victim], and stabbed him multiple times about the upper torso and neck. Lopez was in shock and scared as he watched. Sookram and Lopez then left the premises together through the sliding door and backyard gate.

They entered Sookram’s vehicle and drove to the residence of Lopez’ family at 101 Ashton Crescent in Brampton, a short distance away from the murder scene. Sookram attended inside the residence with Lopez. Sookram stayed for a few hours and was observed by Lopez’s family members. When Sookram departed he left behind the murder weapon – a DeWalt knife – and his black jacket.

On April 8, 2018, Mr. Lopez was investigated by police for an unrelated matter close to the murder scene. He explained to the police that he had information regarding the homicide death of [Victim].

Lopez told police that he gave the murder weapon to his nephew Alfredo Coreas, who subsequently hid the knife at the bottom of an eavestrough drainage spout. The knife was eventually recovered by police. A DNA analysis of the knife linked it to [Victim], Lopez and Coreas.

As a result of a forensic investigation of the murder scene, Sookram’s fingerprint was identified on the back gate of [address redacted], where [Victim] was murdered. The fingerprint impression was in [the Victim’s] blood near the gate latch. Police found blood droplets leading from inside the house towards the back yard gate.

Further investigation also identified the blood of [Victim] on the shoe that was worn by Lopez at the time of the murder.

Lopez’s family members were able to positively identify Sookram as the man who attended at their home after the murder.”

Without Prejudice Positions of the Parties:

6. At the commencement of the hearing, the parties were canvassed for their initial positions.

7. The Hospital took the position that Mr. Sookram continues to meet the threshold for significant threat to the safety of the public, and that the necessary and appropriate Disposition for the coming year is a continuation of the existing Detention Order with no changes to its terms and conditions.

8. Counsel for the Attorney General supported the Hospital’s position.

9. Counsel for the accused advocated for a Conditional Discharge with a residence clause, a consent to treatment term and a Young clause and advised that Mr. Sookram wanted the alcohol prohibition term to be varied to allow for occasional alcohol use.

Evidence at the Hearing:

10. The Board had available to it the evidence and documents forming the Record, the Exhibits, and oral evidence from Dr. Naidoo, who is Mr. Sookram’s attending psychiatrist.

11. Dr. Naidoo testified by way of update to the Hospital Report and provided the following evidence:

a. Mr. Sookram was discharged from the Hospital last July;

b. He requires both oral and injectable antipsychotic medications;

c. He has no civil, community based mental health supports yet established;

d. The staff at First Place, where Mr. Sookram is residing, do a good job of administering medication, but they have limited training in detecting signs of mental status decompensation in patients;

e. Mr. Sookram has developed a fair degree of insight into his mental illness, the symptoms of psychosis, his need for medication and is able to recognize that he was sub optimally treated in the past;

f. He needs more development in domain of insight into the deleterious effects of psychoactive substances on his mental health. Substance abuse was a factor in the index offence;

g. He has been able to maintain abstinence from substances not due to insight or internal motivation, but because of the high degree of support he receives from the forensic outpatient team;

h. The treatment team has a significant concern about Mr. Sookram resuming alcohol use. He is prone to destabilization in his mental status and alcohol is the substance that is most highly correlated to violence, next to methamphetamine. It is a disinhibiting substance;

i. There is clear evidence linking the consumption of alcohol and cannabis to prior violent incidents in Mr. Sookram’s case;

j. He is enrolled in school and is doing quite well;

k. A Conditional Discharge is not appropriate at this juncture for several reasons, including that when unwell, Mr. Sookram’s demeanour changes and he becomes oppositional with his family and his team. The provisions of the Mental Health Act would be insufficient to return Mr. Sookram to Hospital and with sufficient haste;

l. Additionally, Mr. Sookram fairly consistently misses his appointments with the doctor and the team, or asks to reschedule them;

12. In response to questions from the Crown Attorney, Dr. Naidoo provided the following evidence:

a. He agreed that Mr. Sookram’s desire to consume alcohol has been fairly consistent. It raises concerns that he would relapse into substance abuse in general and not limited to abusing alcohol. Alcohol significantly raises his risk of violence toward others, and the influence of peers will likely be a trigger for Mr. Sookram to use substances;

b. Before recommending a Conditional Discharge, Dr. Naidoo would like to see Mr. Sookram continue to reside in his apartment without issue, continue with his education and to prioritize his appointments with the team more, while developing an appreciation for his need for ongoing support.

13. In response to questions from Mr. Schloss, Dr. Naidoo provided the following evidence:

a. He agreed that while under a Detention Order, Mr. Sookram must disclose his forensic status to prospective employers, which leads to some degree of stigmatization, however, Dr. Naidoo explained that SJHH has had tremendous success in getting their patients hired. SJHH has persons who are skilled in navigating disclosure issues and have been consistently successful in selling employers on the stability of their patients and degree of support offered to both patients and employers;

b. The information that must be disclosed is that the patient is a forensic patient, that they committed a violent act and that they are receiving support;

c. Prospective employers and even landlords need to know the circumstances under which they are accepting patients, as well as the risks. Dr. Naidoo also mentioned that for liability purposes these disclosures must be made;

d. Dr. Naidoo doesn’t see any issues with Mr. Sookram having difficulty attending a work site, given his degree of motivation and the fact that his symptoms are largely managed, but noted that employment brings with it additional stressors that can be destabilizing to a patient;

e. Alcohol alone can cause psychosis and auditory hallucinations in some patients. It has psychoactive properties that are distinct from cannabis, and it is disinhibiting, and its consumption can then lead to the use of other substances;

f. Cannabis and alcohol were both factors in the index offence. Mr. Sookram was not medicated at that time;

g. He does not have a history of alcohol use disorder;

h. Dr. Naidoo disagreed with Mr. Schloss’ suggestion that the wording of the Disposition could specify “social” or “moderate” use of alcohol and thereby mitigate the risk to the public posed by Mr. Sookram should he be permitted to consume alcohol. In the opinion of the doctor, persons with substance use disorders should not consume alcohol because they are at a higher risk than the general public for then abusing other substances and Mr. Sookram’s mental illness would be exacerbated by even small amounts of alcohol consumption;

i. There is no reliable way to monitor or quantify Mr. Sookram’s alcohol consumption, and it is necessary that the clause remain unchanged in the Disposition;

j. Canada’s Low-Risk Guidelines are not designed for individuals with mental illnesses and substance abuse disorders. They are designed for the general population to consume alcohol in a manner that reduces their risk of cancer and cardiovascular disease;

k. Addictions are never cured. At best they go into remission;

14. In response to questions from the Panel, Dr. Naidoo testified to the following:

a. Mohawk College is aware of Mr. Sookram’s forensic status, and it would not be a bar for him to participate in a co-op placement. The treatment team could offset any stigma;

b. The use of alcohol can reduce motivation and cause depression symptoms akin to an adjustment disorder and Mr. Sookram has recently reported experiencing depressive symptoms;

c. Mr. Sookram often engages in impression management. He has difficulties expressing when he has setbacks and would neglect to relay information that would negatively affect his liberties, such as when he breached his residence’s rules about smoking indoors. Such impression management can affect how accurate his self-reporting is;

d. Mr. Sookram appears optimally treated at this time;

e. He has been residing in the community for less than a year at the time of the hearing;

f. He has progressed through the forensic system quite rapidly since being found NCR in 2022;

g. The addition of studies to Mr. Sookram’s schedule may become a new stressor. He will be exposed to new peers in classes and at co-ops, and with those new situations will come the temptation to reengage in substance use;

h. Dr. Naidoo is unsure how Mr. Sookram will cope with new stressors and those temptations. Already the team is seeing signs that Mr. Sookram is having difficulty managing competing tasks;

i. If he became unwell, Mr. Sookram’s insight would become impaired, and he would be unlikely to return to the Hospital voluntarily or take his medication and he would become uncooperative with housing staff;

j. Given his apparent cravings to consume alcohol, the team would look at the introduction of anti-craving medication, but doing so would not mitigate the risks that come with alcohol consumption in social settings;

k. Dr. Naidoo agreed that Mr. Schloss’s suggestion that the DO stipulate that Mr. Sookram be allowed to consume alcohol “socially” or in a “moderate” amount is not realistic. Those terms cannot be defined with any specificity, and the Hospital has no way of monitoring Mr. Sookram’s alcohol consumption because alcohol is metabolized by the liver in eight hours and it would take months before his liver enzymes were impacted enough to be measured;

l. Consuming any substances that cause brain damage, such as alcohol, is not advisable for individuals like Mr. Sookram who have both a psychotic disorder and a substance abuse disorder;

m. Mr. Sookram has a reduced seizure threshold because of his mental illness and medication, and alcohol consumption would increase that risk. There is little to no evidence that antipsychotic medications provide a protective effect on the brain when substances such as alcohol are consumed by those with psychotic disorders;

n. Alcohol consumption would significantly increase the risk of violence posed to others by Mr. Sookram;

15. Dr. Naidoo then provided the following points of evidence in re-examination:

a. Mr. Sookram has been entirely abstinent since he came under the auspices of the ORB;

b. PSWs at First Place cannot administer medications as a nurse can. They can simply observe Mr. Sookram taking the medication, but if he diverts it, they would not know. If Mr. Sookram refused to take his medication, then they would advise the Hospital;

c. First Place does not have the ability to use a breathalyzer or similar device to detect alcohol consumption or measure intoxication in Mr. Sookram, and the mere odor of alcohol is not a reliable means of detecting or measuring its consumption;

d. Under a Conditional Discharge, disclosure of one’s forensic status to prospective employers or landlords is not mandatory, but the treatment team has discretion to do so. The exercise of that discretion depends on the nexus between the index offence and the reason for disclosing the forensic status of a patient.

16. At the conclusion of the evidence, all parties maintained their initial positions.

Analysis and Conclusions

17. Having heard and considered the entirety of the evidence as well as the submissions from the parties, the Board finds that Mr. Sookram represents a significant threat to the safety of the public and concludes that a Detention Order Disposition with no changes to its terms and conditions is the necessary and appropriate Disposition that is the least onerous and least restrictive for him in the circumstances.

18. In determining whether Mr. Sookram represents a significant threat to the safety of the public, the Board has carefully analyzed the evidence as it relates to the Supreme Court of Canada decision in Winko, 1999 CanLII 694 (SCC), [1999] 2 S.C.R. 625 and the definition of the term in s. 672.5401 of the Criminal Code. By definition, the term “safety of the public” includes psychological as well as physical harm.

19. A significant threat to the safety of the public cannot be speculative. It must entail a real risk of serious physical or psychological harm arising from conduct that is both serious and criminal in nature.

20. The Panel has come to this decision after a careful review of the Ontario Court of Appeal decision in Ramos (Re), 2025 ONCA 820. While the facts in Ramos differ from those of the present case, the ratio decidendi is relevant to all cases that the Board hears.

21. In summary, the case of Ramos requires the Board to:

22. Remain attentive to constitutional protections and avoid the influence of stereotypes or prejudice;

23. Give thoughtful weight to the reasonable wishes and preferences of NCR individuals, while still prioritizing community safety;

24. Undertake a careful, individualized assessment that avoids assuming permanent or inherent dangerousness and instead evaluates the person’s present clinical and social circumstances;

25. Keep the legal thresholds distinct from hospital preferences or institutional rule compliance, recognizing that clinical convenience cannot substitute for the legal test and conducting a holistic assessment which acknowledges strengths and improvements;

26. Exercise its own independent judgment when reviewing professional opinions; and

27. Approach hearsay evidence with care, ensuring that any reliance on such information is fair, balanced, and consistent with the Board’s dual role of protecting both individual rights and public safety.

28. Having found that Mr. Sookram remains a significant threat to the safety of the public, the next question to be answered is whether the least onerous and least restrictive, necessary and appropriate Disposition is that of a Conditional Discharge or a Detention Order.

29. The Hospital and the Crown Attorney argue for the latter and the accused, the former. The Panel agrees with the Hospital and the Crown for the following reasons.

30. Mr. Sookram suffers from both schizophrenia, a psychotic disorder, and a substance abuse disorder. His psychotic disorder appears well treated with a combination of antipsychotics and the high degree of support he receives from the Forensic Psychiatric Program at SJHH, while his substance use disorder is in remission because of total abstinence.

31. Mr. Sookram, when last untreated and while consuming psychoactive substances such as alcohol and cannabis, committed an act of shocking violence which led to the death of the victim in this matter.

32. When he has been unwell, the uncontradicted evidence of the Hospital is that Mr. Sookram becomes combative with those around him, will not take his medication, will not come to the Hospital voluntarily and would relapse into substance use, thereby causing a rapid decompensation in his mental status and increasing his risk of violence to others. As per the Hospital Report at p. 51:

Considering Mr. Sookram’s current level of protective factors, his historical (static) risk factors and his current/dynamic risk factors, his current level of risk for violence and case prioritization is low. This estimate reflects management of risk associated with psychiatric treatment, positive social support, abstinence, education/employment and lifestyle stability in the context of his ORB disposition. Absent adequate treatment of Schizophrenia, combined with substance use, he may discontinue medication, which has occurred in the past, and in this case the risk of physical harm to others flows from command hallucinations and paranoid [sic]. This risk can include the use of weapons, and thus the potential for serious harm remains part of this risk formulation.

27. Despite his relative stability and rapid progress through the forensic system, there are already warning signs for Mr. Sookram that concern the Panel:

a. He has had recent complaints of depression and requested medication reductions or adjustments;

b. He has had recent and sustained difficulties attending his appointments with the Hospital;

c. He has consistently expressed to the team the desire for consuming alcohol, notwithstanding the fact that the use of alcohol and cannabis contributed to his index offence, which was incredibly violent;

d. The Hospital Report states that Mr. Sookram has asked to decrease his frequency of reporting to the team in order to prioritize his studies, which shows a lack of appreciation for his fragile mental health and the need to prioritize his recovery.

28. It would be helpful perhaps at this juncture to set out the distinctions between a Detention Order and a Conditional Discharge, in order to more clearly explain why the Panel believes that the former – and not the latter – is the least onerous and least restrictive Disposition.

29. The first major distinction between these Dispositions is that once an accused is granted a conditional discharge, they can no longer be detained in the Hospital. If an accused breaches a term in a Conditional Discharge prior to recent amendments to the Code, they could be detained in jail, whereas if one breaches a term in a Detention Order, the result is usually a return to the Hospital.¹

30. A further important distinction between the two Dispositions is the types of terms that may be included in either. Under a Detention Order, community living is a privilege that is usually worded in a manner that requires the Hospital to “approve” the accommodation. Under a Conditional Discharge this term is not available. Similarly, under a Conditional Discharge a clause requiring the accused to consent to treatment can only be imposed with their consent, whereas such a term is not required under a Detention Order.

31. As Michael Davies, Anita Szigeti, Meaghan McMahon and Jill Presser note in their authoritative text A Guide to Mental Disorder Law in Canadian Criminal Justice²:

It may appear at first that a conditional discharge is, by definition, less onerous or less restrictive than a detention order would be. This is not necessarily the case…

32. Ultimately, whether a Conditional Discharge is “less onerous” than a Detention Order depends on the conditions attached to either.³

33. In the recently released Ontario Court of Appeal decision in Singh (Re)⁴, the Court concluded its reasons at paragraph 10 with the following direction to the ORB:

…What was needed is a determination of whether a Young clause – together with the other proposed conditions – could practically and effectively address the risk to the public posed by a comparatively stable NCR accused who meets regularly with the treatment team, is compliant with anti-psychotic medication, whose symptoms are managed well with the current medication regime, and who has a commitment of continuing support from the treatment team. The Board would need to make this determination given the evidence of the nature of the appellant’s particular treatment history and likely clinical path to decompensation…

34. Returning to the case of Mr. Sookram, counsel for the accused proposed that a Young Clause and a treatment compliance condition be added to the Conditional Discharge.

35. In Ramos (Re)⁵, the ONCA directed the ORB to consider a number of factors, including whether the accused would attend the Hospital voluntarily while under a Conditional Discharge. The uncontradicted evidence of the Hospital, including in Dr. Naidoo’s unequivocal answers to questions in his oral testimony at the hearing, was that if unwell and subject to a Conditional Discharge, Mr. Sookram would not voluntarily attend the Hospital.

36. A second important consideration is that even if a Young clause was to be included in a Conditional Discharge, as the ONCA in Ramos pointed out at paras 34-37, such a clause simply gives a Justice discretion to make an order pursuant to 672.93(2) of the Code:

Order of justice pending decision of Review Board

(2) If the justice is satisfied that there are reasonable grounds to believe that the accused has contravened or failed to comply with a disposition or an assessment order, the justice, pending a hearing of a Review Board with respect to the disposition or a hearing of a court or Review Board with respect to the assessment order, may make an order that is appropriate in the circumstances in relation to the accused, including an order that the accused be returned to a place that is specified in the disposition or assessment order. If the justice makes an order under this subsection, notice shall be given to the court or Review Board, as the case may be, that made the disposition or assessment order [emphasis added].

37. Even if a Justice were to issue an Order under this section that directed the accused be returned to the Hospital for a breach of a Conditional Discharge, the process under s. 672.93(2) is not instantaneous. As set out in Ramos, such an Order requires Judicial Authorization. The Hospital (or police) would have to become aware of a breach of the Conditional Discharge Disposition and then seek judicial authorization to have Mr. Sookram apprehended and returned to the Hospital.

38. This process would take time and, when unwell, Mr. Sookram has become extremely combative and extremely violent, a risk that the evidence demonstrates is ongoing. The time required in pursuing this procedure would cause an unacceptable delay in apprehending Mr. Sookram, during which there is a significant risk that he would cause harm or endanger the lives and safety of numerous members of the public and his own family. That is assuming firstly, that a Justice would even order Mr. Sookram back to the Hospital for breaching say, the alcohol prohibition clause in a Conditional Discharge and secondly, that Mr. Sookram does not go AWOL such that he cannot be located by police in a timely manner.

39. Based on the line of questioning from Mr. Schloss, the main reason for advocating for a Conditional Discharge is not that it is somehow less onerous and restrictive than the Detention Order – if the Panel were to grant a Conditional Discharge with the treatment/medication clause and the Young clause, but keep the alcohol prohibition clause, it is difficult to see how it would be – but rather, because the patient does not wish to disclose his forensic status to prospective employers.

40. The Panel agrees with Dr. Naidoo that were the patient given the ability to not disclose his status as a forensic patient, and he were to obtain employment and something go awry, that this non-disclosure would almost certainly open St. Joseph’s Healthcare up to legal liability.

41. The Panel also agrees with Dr. Naidoo that prospective employers or landlords have the right to know who they are taking on and under what circumstances. While Dr. Naidoo acknowledges that the disclosure requirements do create some stigma, he was adamant the Hospital is able to manage any potential consequences to patients.

42. Dr. Naidoo’s evidence that the Hospital has had tremendous success in arranging employment and co-op placements for its forensic patients was uncontradicted. Moreover, there was no evidence presented at the hearing that Mr. Sookram was prevented from availing himself of any opportunities because of the requirement to disclose his forensic status.

43. While the Panel sympathizes with Mr. Sookram in this regard, the safety of the public, including persons in the community and in placement contexts, and the prevention of legal exposure to the Hospital in such circumstances, and the prevention of any legal exposure to the Hospital must outweigh the privacy interest of the patient. Mr. Sookram’s desire to withhold his status as a forensic patient from prospective employers does not justify the imposition of a Conditional Discharge.

44. In short, on the totality of the evidence, a Detention Order is the least onerous and least restrictive Disposition that is still consistent with the factors set out in s. 672.54 of the Code because:

a. The Hospital needs to be able to approve Mr. Sookram’s living arrangement. Mr. Sookram does not fully appreciate the high degree of support he requires and he still engages in impression management rather than disclosing any struggles he endures;

b. Mr. Sookram would not voluntarily return to the Hospital if he experiences a decompensation in his mental status, and there is no guarantee that a Justice would order his readmission to the Hospital under s.672.93 should he breach a Conditional Discharge Disposition term;

c. The Hospital needs the ability to quickly return Mr. Sookram to the Hospital in the event of a decompensation in his mental status, and the delay that would flow from the process set out in Ramos would pose an unacceptable risk of serious harm to members of the public.

45. As it concerns the patient’s request to be allowed to consume alcohol in moderation, the Panel agrees with the Hospital that this is neither realistic, nor in keeping with the paramount consideration for the Board which is to protect the safety of the public.

46. The evidence of Dr. Naidoo on the consumption of alcohol was detailed, unequivocal and uncontradicted:

a. alcohol is an addictive and psychoactive substance which can lead to the abuse of other substances – a “gateway” drug, if you will;

b. Next to methamphetamine, alcohol is the substance most commonly associated with physical violence;

c. The consumption of alcohol was one factor in the commission of Mr. Sookram’s index offence, which was a violent offence that caused the death of an innocent person;

d. Mr. Sookram has a substance use disorder in addition to a psychotic disorder, and his desire to continue to use alcohol, notwithstanding its contribution to his index offence, is alarming;

e. The consumption of alcohol in any amount would independently increase his risk of violence to others, in addition to the indirect risk posed by exacerbating his mental status;

f. The consumption of alcohol is not recommended for persons with psychotic disorders, whose brains are already incredibly fragile.

47. The Panel further agrees that the wording of the Disposition proposed by Mr. Schloss to allow for alcohol consumption is simply unworkable.

48. Phrases such as “social” consumption or “moderate” consumption of alcohol are neither defined nor universally interpreted and are therefore completely unenforceable as a matter of law.

49. Moreover, the Hospital would have no means of quantifying Mr. Sookram’s alcohol consumption. Dr. Naidoo spoke of how quickly the liver metabolizes alcohol for example, as well as how staff at First Place have neither access to nor training for a breathalyser or similar device.

50. Even if they did, anyone with knowledge of the law of impaired driving would know how difficult (if not impossible) it is to correlate blood alcohol concentration with how many alcoholic drinks are consumed.

51. The converse is also true: the Panel could not simply pluck a blood-alcohol concentration (BAC) out of the air and impose that limitation on Mr. Sookram as a compromise solution, because alcohol is metabolized differently by each individual and there would be no way for Mr. Sookram to predict how each individual alcoholic beverage would impact his BAC.

52. In conclusion, the Panel agrees with the Hospital and the Crown that the prohibition on substances in the Disposition Order must stay as is. The proposal by Mr. Schloss is unfeasible for the reasons set forth.

53. The Panel wishes to congratulate Mr. Sookram for another successful year, and to also urge him not to lose sight of the need to continue to prioritize his mental health above all else.

54. In consideration of all the evidence, the submissions of the parties, and the criteria set forth in s. 672.54 of the Code, the paramount consideration being the safety of the public, in addition to the mental condition of Mr. Sookram, his reintegration into society and his other needs, the necessary and appropriate Disposition is a continuation of the existing Detention Order Disposition with no changes.

DATED this 2nd day of June 2026, at the City of Toronto, in the Toronto Region.

Mr. D. D’Intino Legal Member

Office of the Registrar Ontario Review Board

Footnotes

1. 1Ibid at p. 193
2. 22020; LexisNexis Canada Inc at p. 191
3. 3Ibid at p. 194
4. 4Singh (Re), 2026 ONCA 331
5. 52025 ONCA 820