In R. v. Glynn (Ont CA, 2025) the Ontario Court of Appeal considered the purpose of criminal restitution orders:
[9] ... the parties are agreed that the stand-alone restitution order is invalid. This is because, as the Crown acknowledges, the primary purpose of a restitution order is to promote “direct accountability by the wrongdoer to the victim” of the crime by recognizing the “specific harm done to victims and by providing a convenient and inexpensive route by which victims may gain at least some redress for that harm”: R. v. Trac, 2013 ONCA 246, 115 O.R. (3d) 424, at para. 35. The Crown acknowledges that this rationale for a restitution order is inconsistent with the order made in this case, which was in effect to reimburse the investigative police agency, for the costs they undertook to investigate the respondent. On this basis, the Crown requests, and the respondent agrees, that the order should be vacated. In the specific circumstances of this case, we accept this position.
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