Sentence Watch

Indignity to human remains

R. v. Forrest and Russell

Crown askedNot recorded
Judge imposedTime served: 781 days' remand credited at 1.5:1 as 1,172 days1

What the law allows

Maximum5 years
Judge imposed1172 days in custody
For indignity to human remains (CC 182(b)), the Criminal Code currently allows up to 5 years when the Crown proceeds by indictment, with no mandatory minimum. The sentence imposed is 64% of the maximum. Read the section.

Kevin Forrest Jr. and a co-accused pleaded guilty to improperly interfering with human remains after they wrapped the body of a woman who had been killed in a residence and left it in a wooded area. They were not held responsible for her death. Counsel made a joint recommendation; Justice Duncan accepted it and sentenced Mr. Forrest to 1,172 days, deemed served by his 781 days of pre-sentence custody credited at 1.5 to 1.

In the judge's words

In conclusion, the proposed sentences do satisfy the legal requirements to accept this joint recommendation. It is in the range of sentences to be a fit and proper disposition. It reflects due consideration to the applicable principles of sentencing, including the circumstances of the offence and of the offenders.

1

The record

Convicted of
Prior convictions
Not recorded
At the time of the offence
On bail1
Appeal
Not yet checked
Counsel
Crown: Peter Harrison, Bronte Fudge-Lucas
Defence: Noel Fellows (for Forrest); Nicholaus (Nick) Fitch (for Russell)

More cases by The Honourable Justice Patrick J. Duncan

  1. May 1, 2026
    R. v. Caines, 2026 NSSC 146Manslaughter, Sydney
    2 years imprisonment
  2. May 1, 2026
    R. v. MacDonald, 2026 NSSC 126Manslaughter, Glace Bay
    9 years in custody, less 1,526 days credit for remand
  3. October 22, 2025
    R v. Caldi, 2025 NSSC 426Aggravated assault; Assaulting a peace officer with a weapon or causing bodily harm; Possession of a weapon for a dangerous purpose; Possession of a firearm knowing its possession is unauthorized; Breach of a release order, Halifax
    • On release at the time
    9 years' imprisonment (6 years aggravated assault, plus 18 months, 6 months and 1 year consecutive), less 2 years 8 months' credit; 6 years 4 months remaining
  4. August 25, 2025
    R. v. Williams, 2025 NSSC 429Manslaughter; Accessory after the fact to manslaughter, Glace Bay
    11 years' imprisonment (9 years for manslaughter plus 2 years consecutive as accessory after the fact), less 443 days' credit; lifetime firearms prohibition

All cases by The Honourable Justice Patrick J. Duncan (9)

More indignity to human remains cases

  1. February 9, 2026
    R. v. D.A.D., 2026 NSSC 25Arson causing damage to property; Break and enter a dwelling-house; Indignity to human remains, Wolfville. Justice Jamie S. Campbell
    4.5 years in custody (3 years break and enter, 18 months consecutive for indignity to human remains, 18 months concurrent for arson), less 32 days' credit
  2. December 18, 2025
    R. v. Losch, 2025 BCSC 2591Manslaughter; Indignity to human remains, Mission. Justice S. Dev Dley
    • Below the Crown's ask
    10 years for manslaughter plus 2 years consecutive for interfering with human remains (12 years total), less 1,280 days credit
  3. February 6, 2025
    R. v. P.J.L., 2025 BCSC 391Second degree murder; Indignity to human remains, Nanaimo. Justice Robin A. M. Baird
    • Below the Crown's ask
    Life imprisonment, no parole for 12 years; concurrent 4 years for indignity to human remains
  4. December 12, 2024
    R. v. Keyler, 2024 BCSC 2463Manslaughter; Indignity to human remains, Taylor. Justice Ronald S. Tindale
    Dangerous offender: 11 years (4,015 days) less 2,130 days credit, 2 years concurrent, then 10-year long-term supervision order

All indignity to human remains cases (8)

More from the Supreme Court of Nova Scotia

  1. August 5, 2026
    R. v. McLaughlin, 2026 NSSC 260Distribution of cannabis; Breach of trust by public officer, Pictou. Justice Bryna D. Hatt
    3 years custody on each charge, concurrent
  2. August 4, 2026
    R. v. Julian, 2026 NSSC 261Manslaughter, Antigonish. Justice Jeffrey R. Hunt
    • Below the Crown's ask
    • On release at the time
    7 years in custody, less 1364 days' credit for remand (1191 days remaining)
  3. July 31, 2026
    R. v. A.M., 2026 NSSC 262Sexual assault, Sydney. Justice D. Shane Russell
    • Below the Crown's ask
    4 years in custody (2 years consecutive on each of 2 counts), less 1,412 days remand credit; 49 days remaining
  4. July 29, 2026
    R. v. McGrath, 2026 NSSC 265Refusal to provide a sample after an accident causing death, Pictou. Justice Frank P. Hoskins
    • Below the Crown's ask
    4 years' imprisonment on each count, concurrent, then a 4-year driving prohibition

All cases from the Supreme Court of Nova Scotia (144)

More cases in Sydney

  1. July 31, 2026
    R. v. A.M., 2026 NSSC 262Sexual assault. Justice D. Shane Russell
    • Below the Crown's ask
    4 years in custody (2 years consecutive on each of 2 counts), less 1,412 days remand credit; 49 days remaining
  2. May 1, 2026
    R. v. Caines, 2026 NSSC 146Manslaughter. Justice Patrick J. Duncan
    2 years imprisonment
  3. October 30, 2025
    R. v. LeRoy, 2025 NSSC 360Assault causing bodily harm; Aggravated assault; Uttering threats to cause death or bodily harm; Forcible confinement; Robbery; Using a firearm in the commission of an offence; Pointing a firearm. Justice D. Timothy Gabriel
    • On release at the time
    Long-term offender: 10 years imprisonment (counts concurrent, consecutive to sentences already being served), then a 10-year long-term supervision order; lifetime firearms prohibition
  4. March 28, 2025
    R. v. J.D.B., 2025 NSSC 148Possessing child sexual abuse material; Voyeurism. Justice John P. Bodurtha
    • Below the Crown's ask
    18 months in custody (1 year and 6 months consecutive), then 24 months probation

All cases in Sydney (15)

Sources

  1. R. v. Forrest and Russell, 2026 NSSC 51 Court decision, CanLII, January 19, 2026[34] The term “range of sentence” has been discussed today. There is no minimum sentence for this offence; that is, there may be circumstances where a court would not impose a jail sentence.[1] Kevin Forrest Jr. and Cody Alexander Russell are to be sentenced after having entered pleas of guilty to the charge that:[22] It is, as was argued by the Crown, aggravating that at the time of the commission of the offence before the Court, Mr. Forrest was bound by a Release Order dated October 31, 2023, a condition of which was that he keep the peace and be of good behaviour.[65] In conclusion, the proposed sentences do satisfy the legal requirements to accept this joint recommendation. It is in the range of sentences to be a fit and proper disposition. It reflects due consideration to the applicable principles of sentencing, including the circumstances of the offence and of the offenders.[67] Mr. Forrest has been in custody from December 1, 2023, until today (January 19, 2026). This totals 781 days of pre-sentence custody. Allowing for credit of 1.5: 1 day on remand, he has a credit of 1,172 days. In light of this, his sentence is 1,172 days which is considered served by his presence in court.
  2. R. v. Forrest and Russell, 2026 NSSC 51 Court decision, Courts of Nova Scotia

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