In R v Bulic (Ont CA, 2020) the Court of Appeal cited law that disability does not normally factor in to reduce criminal sentencing:
 The trial judge did address the appellant’s mental health issues. He concluded that the issues appeared to be a result of his criminal conduct and not a result of a pre-existing condition. Further, “medical conditions cannot generally be used to avoid what is otherwise a fit and proper sentence”: R v. Heron, 2017 ONCA 441, at para. 25.
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