The Sinister Efforts to Mask Antisemitic Hate
- Mark Sandler
- 1 day ago
- 5 min read
Brothers Razaali and Naveed Bahadur are well-known hatemongers in Toronto. Razaali was convicted of public incitement of hatred against Jews. His vile antisemitic statements targeted Jewish community members and supporters, many of whom were children, attending a vigil for the hostages who, at the time, were being held by Hamas. Razaali referred to Jews as murderers, rapists, filth, and godless. Even more despicable was his appeal to children in the crowd to ask their parents how they raped and murdered children. He was sentenced to 12 months in prison.
Naveed has a well-documented history of unequivocal support for Hamas and its terrorist activities, and of his own efforts to justify the slaughter of Jews as legal resistance. Naveed was at it again when 60,000 Jews and our allies participated in the Walk with Israel.
He is captured on video (see the embedded video below or view it on X) telling anti-Israel protesters how to ostensibly avoid criminal charges. He told them that based on his communication with the police, protesters are free to say anything about Zionism because it is a political ideology.
As a result, as long as protesters describe participants in the walk as Zionists, they can call them “roaches, rats, scum etc.” He also said that “you can say Israel murders kids. But don’t say Israelis murder kids. Because [Israelis] are a protected group.” He cautioned them to make sure not to mention their religion, only that they are all Zionists.
Let’s be clear. Naveed Bahadur has no difficulty inciting hatred against Israelis and Jews. This was all about a sinister attempt to evade criminal liability on his part, and on the part of those assembled. His brother was imprisoned for his blood libels against Jews. This undoubtedly influenced Naveed’s strategic thinking. But their collective views are clear.
The law compels police to look through these transparent efforts to immunize hatred against Jews and Israelis. It is no more lawful to chant “Death to Israel” than “Death to Israelis” when it is clear from the context that the object of this venom is Israelis as a group. It is unlawful to call all Zionists “roaches, rats or scum” when the vast majority of Jews are Zionists. This is incitement of hatred against both Jews and Israelis.
The use of language to attempt to obscure the true target of hateful expression is not merely theoretical. Canadian courts already assess speech by examining its substance, context, intent and effect rather than focusing exclusively on the labels a speaker chooses.
This past year, Nicholas Amor pleaded guilty in a Windsor courtroom to public incitement of hatred against the Jewish community likely to lead to a breach of the peace, as well as possession of a weapon for a dangerous purpose. His online posts repeatedly referred to “Zionists,” whom he described as baby killers, pedophiles, vermin, and targets for violence. Among other statements, he urged others to “Kill Zionists” and called on people to “actively target Zionist entities throughout North America.”
The authorities recognized (and Amor admitted) that he was using the term “Zionist” as a pejorative proxy for Jews. His activities did not amount to criticism or hostility directed against a political ideology in the abstract. The court held that Amor’s conduct was directed at Jewish people. It characterized that conduct as “vile” and “disgusting” and emphasized the danger of holding Jewish Canadians collectively responsible for the actions of the State of Israel. Amor was sentenced to just under two years in prison.
A recent Australian decision also directly addresses the issue raised by Bahadur’s malicious strategy. In March 2025, a Melbourne demonstrator initiated a chant of “All Zionists Are Terrorists.” When proceedings were later brought under Australia's anti-vilification legislation, the respondent argued that the chant was not directed at Jews because “Zionist” and “Jew” are not the same thing. He maintained that his comments were directed only at the Israeli government and its supporters.
The tribunal rejected that explanation. It did not conclude that “Zionist” and “Jew” are synonymous. To the contrary, the tribunal expressly recognized that not all Jews are Zionists and not all Zionists are Jews. That, however, was not the end of the analysis.
The tribunal examined how the words would be understood. It found that Zionism has a deep historical, cultural, religious, and statistical connection to the Jewish people and that there was likely to have been a strong association between “Zionists” and Jewish people in the minds of ordinary participants at the demonstration. The tribunal also examined the significance of the word “all,” finding that it erased distinctions among individuals and transformed a diverse group into a single collective target.
Most importantly, the tribunal evaluated the chant in the context of the demonstration as a whole. It considered surrounding signs, slogans, Holocaust references, Hamas-related imagery, and other conduct occurring at the event. Viewed in its entirety, the tribunal concluded that the chant was likely to incite hatred, serious contempt, revulsion, or severe ridicule against Jewish people.
The significance of the case lies not in any suggestion that criticism of Israel, its government or conduct is unlawful. It plainly is not unlawful – and should not be characterized as such. Rather, the case demonstrates that courts and tribunals should look beyond the terminology employed and examine the overall message being conveyed. A speaker does not necessarily avoid legal liability simply by substituting the word “Zionist” for “Jew” if the surrounding circumstances demonstrate that the speech is directed at Jews or Israelis as a group.
Naveed Bahadur’s approach is not a new one. For example, we have learned about pro-Hamas agitators who spew explicit Jew-hatred in less visible settings, only to use what they regard as more palatable expression when publicly scrutinized.
Bill C-9 (the Combatting Hate Act) also recognizes that one must look to substance, rather than form. It creates a new offence of wilful promotion of hatred through the display, in any public place, of Nazi or terror group symbols. The offence extends to the display of symbols that so nearly resemble a known terror symbol as to effectively amount to a terror symbol. The law cannot be confined to a game of “spot the difference.” If the purpose of a slight alteration is to preserve the hateful meaning while avoiding accountability, the legal system must be capable of addressing that reality, while not overreaching.
The same principle applies to language. A person cannot evade criminal responsibility simply by substituting one word for another if the surrounding circumstances demonstrate that the underlying target and motivation remain the same.
Criminal hate propaganda offences are reserved for extreme speech designed to incite hatred of protected groups, including Jews and Israelis, or promote vilification and detestation of such groups. Jews and Israelis are at particular risk when such hatred is dressed up in increasingly normalized language that masquerades as political commentary. One would hope that the use of language such as “all Zionists are scum, vermin, genocidal, racist, evil or terrorists” or “Death to all Zionists” would be recognized for what it is – dangerous hate speech.
The Naveed Bahadur video highlights the importance of ensuring that police and prosecutors understand the distinction between protected speech and hate speech, and do not give licence to the latter.
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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.