Two of the prohibited conducts (behaviours) listed under Criminal Harassment require “repeated” events in order to fulfill the elements of the offence. The two other prohibited conducts don’t require repeated events as an element of the offence but may require multiple events to prove the intent of the accused.
There have been a number of cases where common law has had to struggle with the legal definition of “repeated” events.
It is possible that two events will satisfy the legal requirement of repeated, or that a single event will meet the requirement of the prohibited conducts that don’t require repetition. Logically the courts willingness to accept the minimal amount of “harassing” is contextual to the event and the serious nature of the harassment. The reason why the Crown may be reluctant to pursue a case with a minimal amount of “harassment” (repeated events) is likely related to proving the intent of the accused. The Crown will want to be able to prove that accused either knew he was harassing or was reckless with regards to the fear his actions would cause. A lovesick party who “watches and besets” the target of their affection may be easily portrayed as odd or weird but will not convince a judge that their actions were criminal unless they had been told to stop.
On the other hand a single shocking and/or intensely threatening event or persistent following on a single event have been considered sufficient for conviction.
Consider how the facts of the case address the issue of intent
Cases of Interest regarding “repeatedly”
R. v. Hawkins 2006 (available CanLII)
R. v. Kosikar 1999 (available CanLII)
R. v. Riossi 1997 (available CanLII)
R. v. O’Connor 2008 (available CanLII)
R. v. Ohenhen 2005 (available CanLII)