Hate Crime & Legal Update: Landmark Sentencing in Canada’s First Wilful Promotion of Antisemitism Case
- Rochelle Direnfeld
- Oct 5
- 6 min read
Week of September 29, 2025
On August 20, 2025, Kenneth Paulin, 51, of North Bay, Ontario pleaded guilty to,
One count of Wilful Promotion of Hatred Against an Identifiable Group (the Jewish Community) and
One count of Wilful Promotion of Antisemitism.
The offence of Wilful Promotion of Antisemitism, the second offence, involves communication that condones, denies or downplays the Holocaust. This offence was added to the Criminal Code in 2022. Paulin’s conviction for this offence is the first of its kind in Canada.
On September 18, 2025, the trial judge accepted a joint submission by counsel for Paulin and the prosecution respecting the appropriate sentence. As a result, Paulin was sentenced to 259 days in custody on each count, concurrent (to be served at the same time), subject to a reduction that takes into account his imprisonment prior to the imposition of the sentence.
Paulin utilized three online platforms, Telegram, Bitchute and Rumble to express his hateful, antisemitic views and Holocaust denial. As described by the sentencing judge:
The content Mr. Paulin created and shared on the platforms targeted Jewish people, dehumanized them, and promoted hatred against them. His online posts described Jews as pedophiles, cockroaches, rats, lizards, vampires and demons; and called them “soulless monsters incapable of empathy or genuine human emotion”.
Mr. Paulin posted content that questioned the overwhelming historical evidence about the Holocaust, downplayed its extent and even called it a hoax. He spread conspiracy theories about the Holocaust that claimed that the atrocities committed against the Jewish people in Europe between 1933 and 1945, as set out in the historical record, were mathematically and scientifically impossible. Some of his posts celebrated Adolf Hitler and the Nazis as the good guys, heroes, deserving of an apology even, in retrospect, as “the last great warriors to fight the Satanic Jewish banking cartels”.
He pushed conspiracy theories claiming that Jews were responsible for “every ill of society” and responsible for such notorious events as the assassination of U.S. President J.F.K., the September 11th, 2001 attack on the World Trade Centre in New York City, and the global Covid-19 pandemic. On this latter point, he referred to the Covid-19 vaccine as the “Jew Jab”, claiming it was designed to harm non-Jewish people. Mr. Paulin posted videos in which he advised he was ready for a revolution, ready to fight back and ready to share his knowledge about how to create explosives and incendiary devices “when the time came”.
In one video, Mr. Paulin spoke with hopeful anticipation of an imminent worldwide pogrom. In another, he posted a computer-generated image of Hitler with a background of ostensibly Jewish men suspended from ropes, with the caption “The Final Solution”. Meanwhile, Mr. Paulin’s voice could be heard referring to a prophecy that claims that “there will be no more Jews after this”.
The court received and relied upon the Community Impact Statement (CIS) authored by the Friends of Simon Wiesenthal Centre. The court found the CIS to be “thoughtful and compelling” and endorsed its declaration that “Mr. Paulin’s accusations of Jewish people are as false as they are grotesque. They are also – and this cannot possibly be overemphasized – historically deadly.
Ms. Kirzner-Roberts on behalf of Friends of Simon Wiesenthal sets out that, “Holocaust denial and glorification are not harmless distortions of history. They are invitations to repeat atrocity”. She characterizes Mr. Paulin’s conspiracy thinking as not just wrong, but dangerous: “It encourages people to see Jews not as neighbours or fellow citizens, but as the hidden enemy behind every problem in their lives, real or imagined.”
The court concluded that Paulin’s propaganda went well beyond the bounds of the vigorous public discourse occurring in Canada and around the world, about the State of Israel’s response to the Hamas attacks of October 7th, 2023, the decisions that have been made by the Netanyahu government or the military operations of the Israeli Defense Forces. The court recognized that Paulin’s offences had a significant impact on the Jewish community in Canada resulting in “enhanced vigilance and fear among community members at a time of already heightened peril.”
The court also recognized that offences such as Paulin’s “engender fear among Jewish Canadians and limit the way in which they associate, express their ethnic and religious identity and practice their religion. This fear undermines their freedoms of association, expression and religion, values cherished by Canadians and enshrined as fundamental freedoms guaranteed by the Charter of Rights and Freedoms.”
Finally, the court found that “hate motivated offences attack the very fabric of our society” and require sentences that reflect the need for general deterrence and denunciation. It was encouraging that the severity of Paulin’s crimes was recognized by the imposition of a real jail sentence, as opposed to a conditional sentence (that is, house arrest).
He was also placed on probation for two years. The detailed terms of his probation order are of critical importance, and include the following:
Not to be within 50 metres of any synagogue, Jewish school, yeshiva, Jewish cemetery, Jewish community centre, or Jewish community organization.
Not to possess any weapon as defined by the Criminal Code, for example a BB gun, pellet gun, firearm, imitation firearm, crossbow, prohibited or restricted weapon, ammunition or explosive substance or anything designed to be used or intended for use to cause death or injury or to threaten or intimidate any person.
Attend and actively participate in all assessment, counseling or rehabilitative programs as directed by the probation officer and complete them to the satisfaction of the probation officer for, but not limited to, trauma. (A reference to the trauma Paulin suffered as a result of voluntarily exposing himself to the propaganda he viewed online)
Not to use or possess any device capable of accessing the internet, including but not limited to computers, smart phones, gaming consoles, tablets (with certain defined exceptions set out in the order)
Not to use any device capable of accessing the internet that:
Has peer-to-peer, torrent or Usenet applications or has any scrubbing software or other services designed to defeat forensic analysis of the internet capable device installed;
Has any program or service designed to allow anonymous use of the internet, for example a Tor browser or VPN, installed; or
Accesses the internet using public WiFi services, internet cafés, or via shared public computers – for example computers at a public library – except one such device as approved by his probation officer and only in the presence of his probation officer for the purpose of journalistic activity, or in the presence of a police officer for the purpose of the deletion of his content and accounts.
Not to access any social media or online messaging platform including, but not limited to, Facebook, Instagram, X (formerly known as Twitter), Snapchat, Tik Tok, Omegle, WhatsApp, Telegram, BitChute, Reddit, Rumble, Wechat, Weibo, QQ, Quora, Discord, Twitch, or Mastodon except in the presence of his probation officer.
Make best efforts in the presence of a police officer, as soon as possible, to ensure the complete deletion of the content and accounts that form the subject of this proceeding on Bitchute Rumble and Telegram.
Significantly, in addition to the above probation conditions, the court ordered, under subsection 320.1(5) of the Criminal Code, the custodians of Telegram and Bitchute to remove Paulin’s accounts. Finally, the court ordered Paulin’s cell phone to be forfeited to he authorities for destruction.
Although in my view, the court could have utilized the case to address more forcefully the scourge of Holocaust denial, minimization and inversion, the sentence imposed sends a strong message that the wilful promotion of hatred and antisemitism should be met with a significant deterrent and denunciatory sentence.
About the Author
Rochelle Direnfeld is ALCCA's Senior Criminal Counsel. She was called to the Ontario bar in 1990 and has served in the Ontario Public Service for over 32 years as an assistant crown attorney, deputy crown attorney, crown counsel, and finally as a deputy director for Toronto Crown Attorneys in the Criminal Law Division of the Ministry of the Attorney General. Rochelle retired from public service at the end of 2023. During her career, Rochelle prosecuted a wide variety of Criminal Code cases in the Ontario Court of Justice, Superior Court of Justice, and the Ontario Court of Appeal.
Rochelle focused a large part of her career on youth criminal justice, developing policy as well as training and lecturing crowns, the defence bar, the judiciary, and the police. Since 2018, Rochelle has been committed to battling hate-motivated offences and has sat on the Attorney General’s Hate Crime Working Group, providing legal advice to crown counsel and police on hate crimes. In the aftermath of October 7, Rochelle returned to work with the Hate Crime Working Group at Crown Law Office - Criminal until November 2024. Rochelle also serves as vice-chair of the Board of Directors of BOOST Child and Youth Advocacy Centre, a wrap-around agency serving children and youth who have been victims of abuse, as well as their families.