Bad-ND · Ontario · Registration revoked
Ontario's College of Naturopaths revoked his certificate of registration in June 2025 after finding thirteen acts of professional misconduct and a breached undertaking. The Divisional Court dismissed his appeal in April 2026. The regulatory paper trail behind it runs back to 1999.
Final outcome
Registration revoked. By order dated 9 June 2025, the Discipline Committee directed the College's CEO to revoke Prytula's certificate of registration, and required him to appear for a reprimand. The panel found him ungovernable.
Costs: $262,953.29 — two thirds of the College's investigative, legal and hearing costs, payable within two years.
Appeal dismissed. Um v. College of Naturopaths of Ontario and Prytula v. College of Naturopaths of Ontario, 2026 ONSC 2417 (Div. Ct.), released 24 April 2026, with a further $12,500 in costs against him.
Nature Medicine Clinic marketed a menu of treatments that Ontario naturopaths are not permitted to provide. According to the College's allegations and the panel's findings, the clinic's website advertised oncothermia, photodynamic therapy for cancer, UV light therapy for cancer, bio-oxidative intravenous therapies, IV chelation, prolotherapy, trigger point injection therapy using lidocaine or procaine, mesotherapy, and platelet-rich plasma therapy.
It went further than listing services. The site told readers that practitioners at the clinic could treat cancer, HIV and AIDS, could kill cancer cells, and that some patients had achieved what it described as complete cancer resolution. The College's Coordinator of Professional Conduct took the panel through those pages. The panel found the language unclear, and capable of confusing and misleading the public.
The controlled acts behind the marketing were real. Prytula admitted compounding blood and plasma, EDTA, oxygen, ozone and procaine, and injecting the same substances — none of which appear on the tables of substances Ontario naturopaths are permitted to inject or compound. He also told an investigator he had taught courses in IV ozone and IV chelation.
The mechanism that made all of this possible, in Prytula's own account, was membership in the Pastoral Medical Association — a private American organization that is not a health regulatory college and does not regulate anyone in Ontario. Patients who signed a PMA agreement became, in the clinic's framing, private "members" rather than patients, and therefore outside the College's reach.
The clinic's website said the quiet part out loud. It told readers that self-government was a joke, that PMA members could obtain health care outside the province's regulatory oversight, and that their files would be protected from prying government eyes. It explained that by leaning on a Doctor of Pastoral Science and Medicine credential alongside the naturopathic licence, more of the practice would fall under the PMA's authority.
When investigators executed a search warrant, they found the structure was literal: two separate databases on the clinic server, one labelled for patients and one for PMA members. A former employee confirmed the files were kept apart because members had been promised the College would never see them — and also confirmed that you could not tell from a file which category it belonged to, or which of the two practitioners had given the treatment.
The panel rejected the whole construct. Membership in a private association does not relieve a registrant of the obligation to obey the law, and a registrant cannot sign away professional obligations by contract. The panel noted that the records themselves undercut the argument: Prytula used his naturopathic title on the PMA charts, the charts made no mention of PMA membership, and nothing in the members' files suggested they understood they were being given treatment outside a naturopath's scope of practice. The panel called the arrangement particularly troublesome, because it placed those members at significant risk.
On the religious framing. Section 27(1) of the Regulated Health Professions Act does permit an unauthorized person to perform a controlled act while treating someone by prayer or spiritual means. The panel heard evidence that the PMA is a Christian-based organization — but found no evidence that any treatment at the clinic was actually provided by prayer or involved any spiritual element. The exemption did not apply.
At the penalty stage the College laid out Prytula's regulatory history to argue that he was not remediable. It is the most useful single summary of how long this went on.
Prytula did not seriously contest the facts. Both he and Dr. Um conceded in their appeal factums that the facts were mostly uncontested and that their defences rested mainly on procedural issues and questions of law. What he argued instead was that the College and its predecessor had permitted his conduct for years by never explicitly telling him to stop — and, in his own words in evidence, that unless he was expressly and explicitly told not to do something, he believed he could do it.
He also told the panel that his authority came from sources outside the Naturopathy Act: his Alberta registration, the Magna Carta, the Oath of Helsinki, the Canadian Bill of Rights, and the private contracts he had signed with PMA members. He told the ICRC that where his oath as a naturopath conflicted with the Bill of Rights, the Bill of Rights would prevail. He described himself throughout his testimony not as a naturopath or a registrant but as an "authorized agent."
The condonation argument died on a five-day exchange of letters from May 2008. On appeal he argued the College was estopped from calling the EDTA undertaking breached, because it had condoned his use of calcium disodium edetate. The Divisional Court held the correspondence was clear: his own counsel had written that he would proceed on that assumption unless he heard otherwise, and Board counsel had replied five days later that the substance was not approved and that accepting the undertaking was not approval of it. The College did not condone it.
Across the merits hearing, the penalty hearing and the appeal, Prytula brought seven separate motions. All failed.
| Motion | Argument | Result |
|---|---|---|
| Charter s. 8 | The search warrant was improperly obtained and executed; exclude the seized records | Dismissed. Warrant properly obtained under s. 77 of the Code; telling him that obstruction could lead to arrest was within an investigator's authority |
| Ultra vires | The CEO's use of "may have committed" meant he lacked reasonable and probable grounds to seek an investigator | Dismissed. The qualifiers reflected that only a panel can find misconduct. On appeal the court called the related arguments largely nonsensical |
| Charter s. 11(b) | Delay amounted to an abuse of process; a potential $35,000 fine is a true penal consequence | Dismissed. Section 11 does not apply to discipline hearings; no inordinate delay, and much of it was caused by his own non-cooperation |
| Charter s. 7 | "Unnecessary treatment" and "including but not limited to" were unconstitutionally vague | Dismissed. Practising naturopathy is a privilege, not a right; no liberty or security interest engaged |
| Bias (December 2024) | The panel made the same errors as the panel in Dr. Um's case | Dismissed. Disagreeing with a decision is not evidence of bias; the remedy is appeal |
| Stay | The misconduct findings were made without jurisdiction | Dismissed |
| Bias (February 2025) | The Chair deferred to College counsel and was "controlled" by her | Dismissed. The transcripts showed the Chair gave him ample opportunity throughout |
On appeal, the bias ground was reframed as an allegation that the two panels had copied one another's reasons. The Divisional Court applied the Supreme Court's test in Cojocaru, along with Gannon v. Windsor Police Service — released the day after this appeal was argued — and counted the overlap. It found the two decisions shared their allegations and legislation sections, as one would expect, but that the evidence summaries genuinely differed. Nothing rebutted the presumption of impartiality.
The College argued there were no mitigating factors at all. It noted that even his admissions had been made without remorse. It argued that a suspension with conditions would be pointless, because remediation assumes a registrant willing to be governed.
The panel agreed. It found the misconduct serious, sustained over a long period, and delivered largely through a website that reached the public directly. It found he had been aware of his professional obligations throughout and had chosen repeatedly to ignore them. It noted that during the hearing itself he made inappropriate comments and refused to confirm his own name at the outset. It concluded it had no confidence he would abide by any penalty short of revocation.
The panel found that his attempt to work outside his regulatory body's control was contrary to law and endangered patients, and that self-regulation only works when registrants follow the rules.
A note from Terry Polevoy, MD
On 12 June 2006 I wrote to the Board of Directors of Drugless Therapy – Naturopathy about Michael Prytula's website. I was not a patient and I had no connection to the clinic. I had simply read the naturomedic.com chelation page.
That page claimed that intravenous chelation had been proven to effectively treat atherosclerosis and gangrene, and that it could dramatically improve the quality of life for people with arthritis, lupus, scleroderma and failing memories. It suggested that if chelation were adopted as standard practice, most coronary bypass surgery could be avoided. None of that was true, and a regulated health professional is not permitted to say it. I told the Board it was a textbook example of consumer health fraud and asked them to investigate immediately.
I raised two other things. The site was using patient testimonials, which regulated health professionals in Ontario are not allowed to do in advertising. And the site was framed around the practitioner's Christian beliefs in a way I thought was inappropriate for a health practice. I also pointed out that if HPRAC went ahead and recommended regulating naturopaths, this clinic would be a prime example of a practice that could not survive under the proposed rules.
My complaint was assigned file number 06-009. The Board wrote to me in January 2008 enclosing its Reasons and Decision. Then I heard nothing further.
In March 2011 I asked the Board's office what had happened. The reply told me that a letter of caution had been issued on some of my concerns, that others had been referred for a disciplinary hearing, and that those had been resolved to the Board's satisfaction. On 31 May 2011 I wrote back asking for a copy of the decision, what the letter of caution actually said, and what the Board had done to make sure it was being followed. I told them my review of his website did not look much different than it had four years earlier. I also asked how many naturopaths had been disciplined or had their registration revoked in the previous ten years.
I never got those answers.
What I did not know until the College published its penalty decision in 2025 is what became of that letter of caution. It is there, in the College's own list of aggravating factors, described exactly as I had framed it: the website's non-compliance with the advertising policy prohibiting testimonials, and the advocating of the health benefits of his Christian belief. The College used it — along with the 1999 undertaking, the 2002 letter of advice, the 2008 EDTA undertaking and the 2019 letter of counsel — to establish that Prytula had been on notice since 1999 and had never changed.
The phrase the Board used with me in 2011, that the matter had been "resolved to the Board's satisfaction," is almost exactly the argument Prytula ran nineteen years later: that his regulators had permitted all of it. The panel rejected that argument, and the Divisional Court rejected it again. But he was not inventing the premise. He was describing how the system had actually treated him.
Nineteen years passed between my complaint and the revocation of his registration. During those years he continued to inject substances Ontario naturopaths are not permitted to inject, continued to advertise cancer treatment, and built an entire private-membership structure designed to put his records beyond his regulator's reach.
Dr. Michael Um practised out of the same clinic and shared responsibility for the same website. He faced substantially the same allegations, was represented by the same paralegal, faced the same College counsel, and was heard by a different panel assisted by the same independent legal counsel. Both men testified at their own hearings and at each other's.
Um was found to have committed the same thirteen acts of professional misconduct. Prytula was found to have committed those thirteen plus a breach of the Compounding Standard of Practice and the breach of his undertaking — which is why one man was suspended and the other revoked. By order dated 29 May 2025, Um's certificate was suspended for eighteen months with conditions imposed, and he was ordered to pay two thirds of the College's costs. His appeal was dismissed alongside Prytula's.
A discrepancy worth noting. The Divisional Court records Dr. Um's costs order as $189,933.49. The College's own Council meeting materials record it as $189,993.49. We have not been able to determine which figure is correct.
A typographical error in the appeal reasons. At paragraph 32, the Divisional Court states that the CEO's September 2019 requests alleged misconduct commencing on or around 1 July 2025. The date should read 2015 — the proclamation of the Naturopathy Act, 2007.
Exhibits. For hearings held after 25 October 2018, exhibits filed with College discipline panels are public. Where they are not posted, they can be requested from the College's professional conduct office.
Concerned about a naturopath in Ontario? The College of Naturopaths of Ontario accepts complaints from anyone. You do not have to have been a patient. Its complaints process is described at collegeofnaturopaths.on.ca. Other provinces have their own regulators.