In R. v. Dawson, 2021 NSCA 29, the Nova Scotia Court of Appeal indicated that the “pandemic has not eliminated carceral sentences. Sentencing during COVID must still respect sentencing imperatives…COVID is a relevant factor in the determination of what constitutes a fit sentence. However, the principles of sentencing, that include denunciation and deterrence, cannot be rendered meaningless. Sparing Messrs. Dawson and Ross from incarceration would have that effect. The pandemic does not create a justification for imposing a disproportionate sentence for significant fraud” (at paragraphs 105 and 106).