The HTA does applies to more than just "highways"

R. v. Hajivasilis, 2013 ONCA 27 holds that some provisions of the Highway Traffic Act can apply to private parking lots:

[4]          I agree with the position advanced by the appellant.  I would hold that the obiter in Shah limiting the operation of the “entire HTA” to “highways” is wrong and should not be followed.  Many provisions of the HTA are by their terms limited to “highways”.  Other provisions, however, are not so limited.  Nothing in the overall structure of the HTA or its purpose compels the reading of the word “highway” into sections in which it does not appear.  Section 199 is one such section.  I would hold that the reporting requirement in s. 199 generally applies even if the accident does not occur on a “highway” as defined in the HTA.