R. v. Morris, 2013 ONCA 223 holds:
 While the trial judge concluded that lack of remission on pre-sentencing custody is not of itself a factor warranting enhanced credit, she also reasoned, at para. 54, that while the appellant was not detained in custody under ss. 524(4) or (8), "the conduct of the accused while on bail prior to revocation, if applicable, may be a relevant factor in determining whether to grant enhanced credit." She concluded that, in this case, the circumstances were analogous to ss. 524(4) and (8), and therefore did not justify enhanced credit.
 We agree.