Hate Crime & Legal Update: Terror Groups, Hate Propaganda, Unlawful Protests and Demonstrations
- Mark Sandler
- Oct 12
- 7 min read
Week of October 6, 2025
R. v. Raazali Bahadur
On October 10, 2025, Raazali Bahadur was sentenced in the Ontario Court of Justice, having been found guilty, after trial of the following:
Public Incitement of Hatred directed at the Jewish community likely to lead to a breach of the peace; and
Fail to comply with a probation order
The findings made by the Court in convicting Bahadur were described in an earlier legal update. Bahadur made a series of hateful comments directed at a gathering of Jews and allies (many of whom were children) attending a vigil held on April 7, 2024, at Nathan Phillips Square commemorating the 6-month anniversary of Hamas’s attack on Israel.
Bahadur’s antisemitic utterances, delivered through an electronic megaphone, included several specifically directed at children attending the vigil. He told the children to ask their parents about the children they raped and murdered (blood and lust libels perpetrated against Jews for centuries.) The Court found these utterances particularly aggravating, not simply for their despicable content, and the children they targeted, but also because Bahadur was on probation at the time for sexual interference (inappropriate sexual conduct with a minor).
At the sentencing hearing, the prosecution sought a 15-month jail sentence, to be followed by three years probation. The defence contended that Bahadur should serve, at most, a conditional sentence (house arrest).
Justice Chapin concluded that the circumstances required her to impose a 12-month jail sentence, followed by three years probation. Her reasons are as important as the disposition.
She first outlined the aggravating factors in the case:
Bahadur’s criminal record,
the fact that he was subject to a probation order at the time of the offence,
his express comments to the children at the vigil,
the fact that the offence took place at a candlelight vigil for the hostages. His conduct amounted to “rubbing salt in the wound” of the participants,
the significant harm to the community as demonstrated by the Community Impact Statements authored by B’nai Brith Canada, the Canadian Antisemitism Education Foundation and the Friends of Simon Wiesenthal Centre as well as the victim impact statements of Matthew Taub and Michael Teper, who were present at the vigil and heard Bahadur’s hateful rhetoric,
the real risk of harm created by Bahadur’s conduct, and
the fact that he targeted the Jewish community, which has been the target of hatred for hundreds of years.
Mitigating factors included Bahadur’s crack cocaine addiction, although the Court rejected his submission that his use of crack cocaine that day explained his conduct. Instead, the Court found that his conduct was planned and deliberate and not the consequence of drug addiction. Bahadur apologized for his conduct but, at the same time, minimized his behaviour and maintained that what he said was not antisemitic and that he was exercising his right to what he believed was free speech in Canada.
Justice Chapin concluded that, over the past number of years, sentences for hate propaganda offences are trending upward, and she cautioned herself against relying on older cases. She also noted that Parliament has recognized the growing problem of antisemitic hate crimes and has introduced new legislation (Bill C-9) to more vigorously address the problem which is “getting worse, not better.” She found that deterrence and denunciation are the primary sentencing principles in this case and that a conditional sentence would not be in the public interest. She easily distinguished this case from one that involved an elderly, ill Indigenous man.
The 12-month jail sentence was accompanied by three years probation, with conditions including: not possessing any weapons, and not being within 50 metres of any synagogue, community centre or facility utilized primarily by the Jewish community.
In conclusion, Justice Chapin’s reasons represent an emphatic statement by a well respected jurist that, subject to very narrow exceptions, real jail is the only appropriate sentence to address hate propaganda targeting the Jewish community at this time.
Hopefully, Justice Chapin’s reasons for sentence and disposition will be treated as an important precedent by other judges in similar cases.
Guilty Plea in Neo-Nazi Terrorism Case
On October 9, 2025, Matthew Althorpe, 29, pleaded guilty in Toronto to multiple terrorism offences, including the commission of an offence for a terrorist group. The terrorist group referred to is the Atomwaffen Division (AWD), a Neo-Nazi group designated by the Canadian government as a prohibited terrorist entity in 2021. The group was founded in the United States in 2013 and operated in several countries.
The Canadian government has described the group as follows:
The group calls for acts of violence against racial, religious, and ethnic groups, and informants, police, and bureaucrats, to prompt the collapse of society. AWD has previously held training camps, also known as hate camps, where its members receive weapons and hand-to-hand combat training.
RCMP investigators have indicated that after AWD was listed as a prohibited terrorist entity, many former members joined, “Active Club Canada.”
The Active Club network is composed of decentralized cells of white supremacist and Neo-Nazi groups, operating in many American states and in Canada. Police advise that the network promotes mixed martial arts to fight a system that supposedly targets the white race, as well as cultivating a “warrior spirit” to prepare for a forthcoming race war.
In July 2025, CBC News reported on the presence of such active clubs across Canada. Antisemitic and anti-immigration themes were described as common features, with some use of Nazi iconography. According to the Global Project Against Hate and Extremism, there are 187 active clubs in 27 countries. One analyst described the very deep connections Canadian active clubs have with other far-right and extremism organizations.
At Althorpe’s guilty plea, the prosecution read into the record a lengthy statement of agreed-upon facts. Althorpe admitted, among other things, that he made videos for AWN showing armed men wearing white skull masks burning religious books, American, Israeli, and Pride flags, accompanied by a narrative calling for a violent race war and an antisemitic epithet. Althorpe can be seen holding a gun in the videos, posted on the social media platform Telegram. He also recruited a small group of Neo-Nazis to train them as a militia.
Althorpe was described as instrumental in creating three influential publications or manifestos promoted through Telegram channels. The manifestos advocated violence, including sabotage of critical infrastructure, murder of police officers, high-profile assassinations, and mass casualty attacks. The prosecutor described the content of the manifesto Althorpe authored to include “radically antisemitic” material, and incitement to attacks against LGBTQ+ individuals, Jews and people of colour.
Perhaps most significant to me, the materials have been cited by at least five people who committed acts of terrorism, including someone who shot two people outside a gay bar in Slovakia in 2022 and a young person who stabbed five people near a mosque in Turkey. It is yet another reminder of the dangers associated with hate or terrorism-related propaganda in motivating others to commit violent, sometimes murderous acts, against vulnerable communities. The Jewish community is seemingly never exempted.
Althorpe has remained in custody since his December 2023 arrest. The prosecution will be seeking a 20-year prison term.
This case also reinforces the need for accountability for social media platforms that facilitate the spreading of hatred and the promotion of terror.
In a subsequent editorial, we will address the steps that should be taken to address this continuing issue.
Toronto Arrests in Protests/Demonstrations
On Thursday, October 9, 2025 at approximately 11:30 a.m., Toronto police responded to a call for a protest in the Bloor Street West and Dorval Road area.
It is alleged that:
approximately 30-40 people attended MP Karim Bardeesy's constituency office and forced their way into the common area
the lone staff member retreated to a room and called 911
police attended and escorted the staff member to safety
officers directed all individuals to vacate the premises
eight individuals refused to comply and were placed under arrest
Canadian Press reported that a pro-Palestinian activist group had announced plans to attend the MP's constituency office to urge the government to take action respecting Israel’s interception of a flotilla bringing aid to Gaza.
Faisal Ibrahim, 39, Chloe Tse, 24, Matthew J Goodings, 59, Francois Villeneuve, 48, Atia A Haq, 38, Susan Goldstein, 67, Alexander Vesuna, 30, Michael DeForge, 38, have been charged with:
Forcible Entry
Unlawful Assembly
Mischief
Obstruct Peace Officer
They are scheduled to appear in court at the Ontario Court of Justice, 10 Armoury Street, on November 25, 2025 at 2 p.m.
On Wednesday, October 8, 2025, police were in the vicinity of University Avenue and Richmond Street West for a demonstration.
It is alleged that:
at approximately 7:45 p.m., police officers were managing the demonstration
a group of demonstrators deliberately obstructed a major intersection, impeding the flow of traffic
when officers issued lawful instructions directing demonstrators to clear the roadway, some individuals refused to comply and remained uncooperative
all the accused parties actively interfered with officers in the execution of their duties.
as a result of their actions, the accused were subsequently placed under arrest.
Ashley D'Souza, 26, Althea Draghici, 22, Nafeesa Alibhai, 25, and Mary-Grace Ommert, 22, were charged with:
Member of Unlawful Assembly
Common Nuisance
Obstruct Peace Officer
They are scheduled to appear in court at the Ontario Court of Justice, 10 Armoury Street, on November 25, 2025, at 11 a.m.
Nicole Maxwell, 33, Eileen Lin, 23, and Reza Sherzad Hashemi, 31, were charged with:
Member of Unlawful Assembly
Common Nuisance
Obstruct Peace Officer
They are scheduled to appear in court at the Ontario Court of Justice, 10 Armoury Street, on November 26, 2025, at 11 a.m.
Rawan Habib, 29, and Nathan Prather, 22, both of Toronto, were charged with:
Member of Unlawful Assembly
Common Nuisance
Obstruct Peace Officer
They are scheduled to appear in court at the Ontario Court of Justice, 10 Armoury Street, on November 28, 2025, at 11 a.m.
As reflected in ALCCA's newsletter, we have repeatedly raised concerns with police and governments about underutilizing existing criminal law measures to address unlawful protests or demonstrations, including blocking of intersections and interfering with the lawful use and enjoyment of property by others.
These criminal measures include the offences of unlawful assembly, mischief, common nuisance, use of disguise during an unlawful assembly and intimidation. It is therefore appropriate to acknowledge the increased use of these measures in recent months.
We make no comments on the merits of charges in individual cases currently before the courts.
About the Author
Mark Sandler, LL.B., LL.D. (honoris causa), ALCCA’s Chair, is widely recognized as one of Canada’s leading criminal lawyers and pro bono advocates. He has been involved in combatting antisemitism for over 40 years. He has lectured extensively on legal remedies to combat hate and has promoted respectful Muslim-Jewish, Sikh-Jewish and Black-Jewish dialogues. He has appeared before Parliamentary committees and in the Supreme Court of Canada on multiple occasions on issues relating to antisemitism and hate activities. He is a former member of the Ontario Human Rights Tribunal, a three-time elected Bencher of the Law Society of Ontario, and recipient of the criminal profession’s highest honour, the G. Arthur Martin Medal, for his contributions to the administration of criminal justice.