Victim Fine Surcharge

Tinker v. The Queen, 2014 ONCJ 208:

Applicants have brought an application under the Canadian Charter of Rights and Freedoms challenging the s. 737 Victim Surcharge amendments, which came into effect on Oct. 24, 2013. Notice under the Courts of Justice Act s. 109 -- " I hold that the requirement in s. 737(2)(b) for a surcharge, where no fine is imposed on the offender, does infringe s. 7 of the Charter and cannot be saved by s. 1."