Crown prosecutor Erin Woolley said the offending was the "fourth time now of the exact same type of offending".
"How do we address the risk of this happening again?"
Justice Whata added: "I'll be frank, it doesn't seem that supervision has worked."
Patel's latest offending saw him target a young woman and her sister at Event Cinemas at Westgate in Massey.
After walking past several empty seats he sat next to his victim, the court heard.
After looking at her several times he slid his hand along the seat and underneath her bottom.
"She asked what you were doing and told you to move," Justice Whata said.
Patel moved one seat away from his victim, but her sister told him to leave the cinema.
When spoken to by police, Patel said he had issues with anxiety and cannot control his hands.
The court heard that the victim struggles with the event and to visit cinemas.
While Justice Whata described the latest offending as a "fleeting touch" it had understandably left the victim feeling "violated and completely unsafe".
"It has affected her outlook on life and made her very mistrustful of people," the judge said.
Patel's lawyer, John Anderson, said his client was offering an emotional harm payment of $500 to the victim.
A psychiatric report said Patel has strong compulsion issue which led him to and touch others and stroke their hair. However, the urge was mitigated if he took medication, the court heard.
Patel was convicted of the first two incidents in May 2014 and given a first-strike warning.
He was sentenced to 18 months' intensive supervision, 230 hours' community work and ordered to pay reparation.
In January 2017, Patel was again caught in a movie theatre - this time rubbing a girl's thigh.
He was given a verbal second-strike warning but it became void after a written warning was not sent to him.
Today, after the fourth incident, Patel was sentenced to five months' home detention and ordered to take his medication by Justice Whata.
"If you do this again you will be sentenced to a term of imprisonment of seven years," the judge said.
Patel, who continues to work as an accountant, has also been convicted of being in a property unlawfully, driving while disqualified, drink driving and offensive behaviour.