Lex Pundit
CriminalSettled framework

Sentencing Indigenous offenders

When sentencing an Indigenous offender, a judge must consider their background and circumstances and all available alternatives to imprisonment.

Position current as of July 2026

Current position

Section 718.2(e) of the Criminal Code directs that all available sanctions other than imprisonment that are reasonable in the circumstances should be considered, with particular attention to the circumstances of Indigenous offenders.

Courts must take into account the systemic and background factors that may have played a part in bringing the offender before the court, and consider sentencing procedures and sanctions appropriate in the circumstances — an analysis that applies to every Indigenous offender and every offence.

Governing authority
R v Gladue
[1999] 1 SCR 688

Gladue interpreted section 718.2(e); Ipeelee reaffirmed that the analysis applies in every case.

Key cases
Supreme Court of Canada
R v Gladue
[1999] 1 SCR 688 · Apr 23, 1999

Interpreting section 718.2(e) of the Criminal Code, the Court held that judges must pay particular attention to the circumstances of Indigenous offenders when sentencing, considering their background and alternatives to imprisonment.

Supreme Court of Canada
R v Ipeelee
2012 SCC 13 · Mar 23, 2012

The Court reaffirmed and strengthened the Gladue principles, holding that sentencing judges must take judicial notice of the history and circumstances of Indigenous peoples and apply the analysis in every case, including for serious offences.

How the law evolved
1996
Section 718.2(e) enactedStatute
Parliament directs particular attention to Indigenous offenders in sentencing.
1999
R v GladueLeading case
[1999] 1 SCR 688
The provision is interpreted as a remedial response to over-incarceration.
2012
R v Ipeelee
2012 SCC 13
The Court reaffirms the analysis and rejects a serious-offence exception.