In R. v. R.S. (Ont CA, 2023) the Court of Appeal applied an existing Charter ruling prohibiting "mandatory imposition of a victim fine surcharge":
 ... The Crown further agrees that in light of the decision of the Supreme Court of Canada in R. v. Boudreault, 2018 SCC 58,  3 S.C.R. 599, which held that the mandatory imposition of a victim fine surcharge is contrary to the Charter, the victim fine surcharge imposed on the appellant should be set aside.
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