GUILTY or NOT?

GUILTY or NOT? / Case library / Homicide

The Naturopath's Needle

R v Javanmardi (2019)

Charge: Criminal negligence causing death (s. 220) and manslaughter by way of an unlawful act (ss. 222(5)(a), 234, 236) Court: Supreme Court of Canada Province: Quebec Heard on GUILTY or NOT?: 26 October 2026

The facts

The Accused had run a naturopathic clinic in Quebec since 1985. She held a science degree from McGill, a doctorate in naturopathic medicine from a recognized college in Oregon and a further diploma involving 500 hours of coursework, including classes and clinical training in intravenous injection. She had treated four or five thousand patients and, since 1992, had given about ten intravenous nutrient injections a week. Naturopaths may lawfully do that in most provinces, but not in Quebec, where it is contrary to the Medical Act. In June 2008 an 84-year-old man with heart disease, frustrated with conventional medicine, came to her with his wife. After an hour-long consultation she recommended intravenous nutrients. She told him she did not normally inject on a first visit; he insisted. She mixed the solution from separate vials. One vial of L-Carnitine had already been used on two other patients that day without incident. It was contaminated. The patient reacted almost immediately, hot and nauseous. She stopped the drip and checked his vital signs, which were stable; there was no fever, no confusion and no sign of infection at the site. No patient of hers had ever developed an infection. She thought it might be low blood sugar and gave him honey and orange juice. He said he did not want to go to hospital and his family took him home. Later that day she told his daughter to keep him hydrated and to take him to hospital if she could not. That night his daughter called an ambulance. He died some hours later of endotoxic shock. She was charged with criminal negligence causing death and with manslaughter.

You have the facts the court had. Did the Crown prove it beyond a reasonable doubt? Render your verdict in the game, then see what the court actually decided — and why.

Citation: R v Javanmardi, 2019 SCC 54

Read the full decision at decisions.scc-csc.ca. The source reveals the outcome.