R. v. Fernandes, 2013 ONCA 436 holds:
 It is also important to emphasize that driving prohibition orders under theCode, and provincially-imposed driving suspensions or restrictions are different in character and serve discrete purposes. Driving prohibition orders under theCode form part of a sentencing judge's arsenal of sanctions on sentencing an accused for a criminal driving offence. In some instances, the imposition of a driving prohibition order is mandatory for such a conviction; in other instances, it is a discretionary sanction that may be imposed by the sentencing judge when crafting a fit sentence: see ss. 259(1), (2) and (3.1) to (3.4) of the Code. The important point is that, whenever imposed, a driving prohibition order under theCode is part of the penalty or punishment imposed for a criminal driving offence.
 In contrast, provincial driving suspensions or restrictions do not constitute any part of a penalty or punishment imposed by the criminal law. Rather, they are a form of civil driving disability arising out of a conviction for a criminal offence. I endorse Durno J.'s observation in R. v. Wilson, 2011 ONSC 89, 270 C.C.C. (3d) 110, at para. 29, citing Prince Edward Island (Secretary) v. Egan,  S.C.R. 396: "[t]he provincial suspension is not a sanction that is imposed in furtherance of the purposes and principles of sentencing … It is not part of the federal criminal law power and not imposed in furtherance of the purposes and principles of sentencing."