Re Ankurbhai Patel, 2026 CanLII 59655

Re: Ankurbhai Patel

ORB File No: 7805

Hearing held on: Friday, May 22, 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: Hon. Justice B. Allen Dr. G. Eayrs Dr. M. Mamak Ms. B. Naegele

Parties Appearing:

Accused: Ankurbhai Patel Counsel: Ms. R. Levin

The person in charge of hospital: Counsel: Ms. M. Warner

Attorney General of Ontario: Counsel: Ms. L. Earle (by Zoom)

REASONS FOR DISPOSITION

(Dated June 16, 2026)

Introduction:

1. On November 10, 2020, Ankurbhai Patel was found not guilty by reason of mental disorder (“NCR”) of charges of possession of weapon for a dangerous purpose, utter threat, assault with a weapon, and assault causing bodily harm, contrary to the Criminal Code of Canada.

2. Mr. Patel is currently subject to a Disposition of the Ontario Review Board (“ORB” or the “Board”) dated May 27, 2025, which discharges him subject to a variety of terms and conditions, including that he reside at a specified address and that he report to the person in charge of the Centre for Addiction and Mental Health (“CAMH” or the “hospital”) not less than twice per month. The Disposition also contains a condition that he take treatment as prescribed in accordance with s.672.55 (1) of the Criminal Code. There is also a condition prohibiting Mr. Patel from being in possession of a weapon and a condition that requires he abstain from the non-medical use of alcohol, drugs or any other intoxicant.

3. On May 22, 2025, a panel of the ORB convened an annual hearing to review Mr. Patel’s Disposition pursuant to s.672.81(1) of the Criminal Code. Mr. Patel attended the hearing and was represented by his counsel, Ms. Levin. He was assisted at the hearing by a Gujarati interpreter, who provided interpretation on an as-needed basis. Mr. Patel’s wife was also present at the hearing.

4. The issues to be decided at this hearing were whether Mr. Patel continues to meet the test for significant risk to the safety of the public and, if so, a decision as to the least onerous and least restrictive disposition to be made in the circumstances of this accused, including any conditions to be attached to that Disposition, bearing in mind the four factors set out in s. 672.54 of the Criminal Code.

5. For the reasons set out below, the Board was in unanimous agreement that the test for significant threat continued to be met and that the least onerous and least restrictive Disposition necessary to manage the risk posed to the public by Mr. Patel is that he remains subject to his existing Conditional Discharge except for a reduction in the frequency of his reporting to not less than once a month or as required.

Positions of the Parties:

6. At the commencement of the hearing, all parties were canvassed as to their position. The hospital’s representative recommended that Mr. Patel continues to represent a significant threat to public safety and that he should remain bound by the terms of his existing Disposition except for a reduction in the frequency of his reporting to not less than once a month or as required.

7. Counsel for the Attorney General supported the hospital’s recommendation.

8. Counsel for Mr. Patel indicated her client was supportive of the hospital’s recommendation, including Mr. Patel’s consent to the treatment condition.

9. At the conclusion of the evidence, all parties maintained their joint recommendation.

Personal History:

10. Mr. Patel is a 40-year-old man who is a permanent resident of Canada. He migrated from India in 2014. Since October 8, 2021, he has lived with his wife, the victim of the index offences. He works full time for his brother-in-law in a factory. There are no children.

11. The index offences occurred December 24, 2019. Mr. Patel was granted bail on February 11, 2020. He lived with his sister, brother-in-law, their two children until October 8, 2021, when he was permitted to live with his wife subject to her consent as provided in his Disposition.

12. Mr. Patel has a history of heavy alcohol use since moving to Canada in 2012. He reported being abstinent for a brief period of time before the index offences. Mr. Patel has a remote history of cannabis use.

Current Diagnoses:

13. Mr. Patel’s current diagnoses are:

• Schizophrenia; and

• Alcohol Use Disorder, in remission.

Query/Rule out mild intellectual disability vs unspecified mild neurocognitive disorder.

Index Offences:

14. The facts surrounding the index offences are set out in last year’s ORB Reasons dated June 18, 2025, as follows:

“According to the police report, on December 21, 2019, Mr. Patel was watching television with the victim, his wife Ms. Nilamben Patel, at their shared apartment residence in Toronto. Without warning, Mr. Patel demanded for the victim to surrender all of her “black cards” in her wallet as he feared that unknown persons were using them to track the victim’s whereabouts. Without allowing the victim any time to react, Mr. Patel attempted to stab her in the stomach with a recently purchased knife. The knife was still enveloped by plastic sheathe, which prevented the victim from sustaining severe injuries. The victim fell onto her back and Mr. Patel again attempted to stab her. The victim sustained multiple lacerations to her forearms. Mr. Patel then chased the victim with the knife and threatened kill her if she did not give him her “black cards”. The victim was able to grab the knife blade and wrestle it from him. She fled to a relative’s residence in the area and contacted the police. Mr. Patel was apprehended and charged with Assault with Weapon, Assault Cause Bodily Harm, Possession of a Weapon, and Uttering Threat.”

Evidence at the Hearing:

15. Dr. A. Igoumenou, Mr. Patel’s out-patient psychiatrist since January 21, 2025, testified at the hearing to supplement the documentary information available to the Board. She adopted the contents of the Hospital Report, and advised there were no material updates thereto.

16. Mr. Patel is assessed as capable to consent to his psychiatric treatment and he self-administers an oral dose of the antipsychotic medication, risperidone, nightly, monitored by his wife. His mental state has been stable and he denies experiencing any psychotic symptoms, including hallucinations or other disturbances. He has not presented with any bizarre behaviour or preoccupation with investments. There have not been any readmissions to the hospital over the year in review nor have there been any concerns about aggression or violence. No changes were made to Mr. Patel’s medications over the review period. Mr. Patel’s illness appears to be in sustained remission due to his consistent medication adherence and his abstinence from alcohol and drugs.

17. There have not been any concerns raised by Mr. Patel’s wife regarding his medication adherence; however, there was one occasion in February 2026, when his urine test did not reveal any traces of risperidone or its metabolite. Mr. Patel had no explanation for this aberration. He simply advised that he had been fully compliant with his medications. Of note, Dr. Igoumenou did not note any change in his mental state at that time. Dr. Igoumenou stated that a treatment goal moving forward will be to improve Mr. Patel’s insight regarding the importance of on-going consistent treatment compliance.

18. Mr. Patel is followed in the community by the Forensic Outpatient Service (“FOP”) team and he has reliably attended all appointments, which are typically every two weeks. As Mr. Patel works full-time, many of his appointments were virtual. Mr. Patel sees his psychiatrist at least monthly.

19. All of Mr. Patel’s urine drug screens during the reporting period have returned negative for substances of abuse. He is randomly tested on at least a monthly basis.

20. Mr. Patel and his wife travelled to India for four weeks (January to February 2026) to visit family and the trip went well. Mr. Patel was able to check in with his FOP team online during that time and no concerns were raised.

21. Mr. Patel continues to reside in an apartment in Toronto with his wife who is a very strong support. In February 2025, Mr. Patel’s in-laws moved from India to stay with his wife and him for several months. Mr. Patel and his wife were happy with their visit and expressed being grateful for the support.

22. The team has had regular contact with Ms. Patel and she reports that her husband has been mentally stable and their relationship has been positive and she has not expressed any safety concerns.

23. Mr. Patel was consistent in attending his appointments with the clinical team. He participated in individual therapy sessions with FORCAT, and he attended four sessions; however, he did not complete the courses and stopped engagement after returning from India. More recently, he has agreed to be re-referred to FORCAT. Dr. Igoumenou stated that a focus for the year ahead will be to have Mr. Patel re-engage and complete the individual therapy sessions with FORCAT focused on Cognitive Adaptation Therapy and to address relapse prevention. The doctor advised that Mr. Patel can complete this process on-line. Dr. Igoumenou also advised that the hospital can provide interpretation services to him during these sessions, if requested.

24. Mr. Patel works full time at his brother-in-law’s company. He spends the rest of his time in his apartment with his wife or running errands with her. Overall, he has a very supportive family that is actively involved in his mental health and recovery.

25. When discussing his cognitive deficits, the doctor opined that these deficits are likely due to a mixture of his premorbid intellectual functioning and residual symptoms of Schizophrenia. The doctor stated that is one reason why the team recommends he engage in ongoing individual therapy.

26. According to the Hospital Report, the clinical factors most relevant for Mr. Patel include:

• history of violence influenced by delusional beliefs;

• limitations on insight into treatment;

• tendency to minimize stressors and psychotic symptoms when unwell; and

• history of alcohol misuse.

27. Dr. Igoumenou adopted the Risk Assessment contained in the Hospital Report, as follows:

“In risk assessment, one of the best predictors is a patient’s history of violence. Mr. Patel’s offences occurred when he was in a psychotic state and non-complaint with recommendations by his family to seek help. If Mr. Patel were to re-offend, this will likely transpire in the following manner:

Mr. Patel would experience a relapse of psychotic symptoms, as a result of medication

non-adherence, substance use, spurred on by stress, or occur spontaneously without obvious triggers. In such a scenario, he will progressively become more fixated on acquiring his father’s property in India and other ways to make money quickly. His delusions will likely progress to developing paranoid beliefs that others are tracking or following him, with concerns about “black money” or “black cards.” He is likely to experience referential delusions such as receiving specific messages from the TV or from strangers, which would likely intensify his paranoia, and he would act out violently. The victims most likely to be harmed are individuals in Mr. Patel’s proximity, such as family members.”

28. When asked what would occur should Mr. Patel suffer a decompensation in his mental state due to medication non-adherence, relapse to alcohol or substance use, and/or breakthrough symptoms, the doctor stated that Mr. Patel has assured the clinical team that he would cooperate in a return to hospital if requested. The clinical team is also confident that they would be assisted by his wife who is insightful regarding her husband’s illness and who has indicated that she would contact the team with any concerns with Mr. Patel’s mental health, as she has done in the past.

29. In response to a question from a panel member related to the proposed reduction in Mr. Patel’s reporting requirement, the doctor expected he would be fully compliant and cooperative in being seen even more frequently should that be requested.

30. No further evidence was called by the parties.

Analysis and Conclusions:

31. The Board finds that the test for significant threat is made out in this case. Mr. Patel has a history of psychosis and of assaultive behaviour flowing from delusional thoughts when unwell. His delusions, when active, are very expansive. Mr. Patel’s insight into his mental illness and need for treatment dissipates when he suffers from active symptoms of his illness, elevating his risk to others. Absent external controls, medication, supervision and support, Mr. Patel is at risk of decompensation and the violence he exhibited in 2019.

32. Having come to a finding of significant threat, we must craft a Disposition that is necessary and appropriate, as well as least restrictive, and least onerous. We find that the Mental Health Act is sufficient to manage his risk to public safety together with Mr. Patel’s existing Conditional Discharge save and except for a reduction in the frequency of his reporting to not less than once a month, or as required. The doctor’s evidence was clear that Mr. Patel has always been cooperative with the treatment team and he would be highly likely to agree to increase his contact with the FOP if that was recommended to him at a later date.

33. Mr. Patel is fortunate to have the support of his wife and their extended family who are supportive of his recovery. His wife, in particular, is keenly aware of his mental health challenges and she plays an important role in supporting him. Historically, Ms. Patel has reached out to the FOP team when she had concerns about her husband’s presentation and she has expressed that she can be relied upon to do the same going forward should her husband suffer any decompensation in his mental health.

34. The Board congratulations Mr. Patel for his progress over the past reporting year.

35. In making this Disposition, the Board has reviewed the provisions of s. 672.54 of the Criminal Code and has carefully considered the need to protect the public from dangerous persons, Mr. Patel’s mental condition, his reintegration into society and his other needs.

DATED this 16^th^ day of June, 2026, at the City of Toronto, in the Region of Toronto.

Ms. L. Banks

Alternate Chairperson

__________________

Office of the Registrar

Ontario Review Board