Ontario Tribunal Revokes Counsellor's Registration for Boundary Breach
Case Law

Ontario Tribunal Revokes Counsellor's Registration for Boundary Breach

Canada·Wire Summary⏱️ 3 min read

Discipline panel notes she exchanged hundreds of informal messages and calls with client A tribunal ordered the revocation of the registration certificate of a registrant of the College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario for crossing professional boundaries in her relationship with her client and his spouse. The cases were College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v Hamouche, 2026 ONRPDT 10 , and College of Registered Psychotherapists and Registered Mental Health Therapists of Ontario v Hamouche, 2026 ONRPDT 11 . On May 26, 2021, the registrant received her certificate from the college in the qualifying class. She had yet to fulfill all the requirements for full independent practice. On June 26, 2025, the Inquiries, Complaints and Reports Committee (ICRC) considered a registrar investigation into claims that the registrant had violated boundaries with her client and his spouse and had falsified a college document. The ICRC referred the boundary violation matter to the Ontario Registered Psychotherapists Discipline Tribunal. Alleging that the registrant was ungovernable, the college requested the revocation of the registrant’s certificate. The discipline tribunal proceeded without the registrant’s participation, given that she had failed to answer the college’s inquiries, respond to the request to admit, appear at the hearing, or attend an ICRC-ordered oral caution. The registrant also did not fill out her annual renewal form or pay her annual registration fees for 2025–26. The Ontario Registered Psychotherapists Discipline Tribunal directed the registrar to revoke the registration certificate and ordered the registrant to pay the college’s costs of $4,700. According to the tribunal, revocation would protect the public and promote confidence in the college’s ability to regulate the profession in the public interest. In imposing this penalty, the tribunal considered the registrant’s serious misconduct, the absence of evidence that she would be an appropriate candidate for remediation, and her lack of involvement in the investigation and disciplinary processes. The discipline tribunal determined that the registrant: “The misconduct and the registrant’s non-participation in the disciplinary process show a pattern of conduct that demonstrates that she is not prepared to recognize her professional obligations and the regulator’s role,” the discipline tribunal’s panel stated. Relying on deemed admissions from the request to admit, the tribunal held that the registrant engaged in professional misconduct under s. 51(1)(c) of the Health Professions Procedural Code, schedule 2 to Ontario’s Regulated Health Professions Act, 1991. The tribunal concluded that the registrant violated s. 1 of Ontario Regulation 317/12, made under Ontario’s Psychotherapy Act, 2007, by: Here are some other decisions by the Ontario Registered Psychotherapists Discipline Tribunal. On Nov. 19, 2025, a panel of the tribunal imposed a five-month suspension on a registrant who engaged in a dual relationship with two clients who were mother and child, resulting in a conflict of interest. On Aug. 25, 2025, the tribunal found professional misconduct on the part of a registrant who failed to file a mandatory report to the relevant regulator regarding the sexual abuse allegedly perpetrated by a registered massage therapist. Enjoy this story? Read the latest medical malpractice law news on the main page! The Canadian Legal Newswire is a FREE newsletter that keeps you up to date on news and analysis about the Canadian legal scene, providing targeted news and information of interest to Canadian Lawyers. Please enter your email address below to subscribe.

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