Rule against multiple convictions applies to regulatory matters

R. v. Ralph, 2013 NLCA 1 is a source for the principle that the rule against multiple convictions applies to regulatory matters:

 

[26]        The rule against multiple convictions was set out in R. v. Kienapple, 1974 CanLII 14 (SCC), [1975] 1 S.C.R. 729 and in R. v. Prince, 1986 CanLII 40 (SCC), [1986] 2 S.C.R. 480.  Under the approach laid out by Dickson C.J.C. in Prince, multiple charges relate to “the same cause or matter” if two requirements are satisfied.  First, there must be a factual nexus between the charges, so that the same act grounds each charge. Second, the second offence must not contain any additional element that distinguishes it from the first offence.

 

[27]        The rule against multiple convictions applies to regulatory offences as well as criminal offences.  In McKinney v. The Queen, 1980 CanLII 164 (SCC), [1980] 1 S.C.R. 401, the accused were convicted of hunting out of season and hunting at night with lights.  Laskin C.J.C. in a brief oral decision, upheld the decision of the majority of the Manitoba Court of Appeal that the convictions were consistent with the rule against multiple convictions as they involved separate delicts.