The accused appealed two incidents of obstructing police contrary to s. 129 of the Criminal Code. In the first incident a vehicle was observed in poor condition without a front plate. The accused was requested to stop and pull over. The accused was unable to produce a licence, permit or insurance. Believing that the vehicle was uninsured, the officer said the vehicle would be impounded. The accused had 3 priors for operating without insurance. The accused refused to get out of the car. He locked the doors. After being served, he drove off into a private laneway where it could not be towed. In the second incident, the accused originally drove off but later stopped. He could not produce insurance. The officer knew his licence had been obtained by falsely claiming to have insurance. A dealer's plate was inside the vehicle. The accused exited the car, locking the keys inside. While the police did not have the statutory power to impound an uninsured vehicle, the police were engaged in the lawful execution of their duties derived from their ancillary powers at common law. Uninsured vehicles cannot be tolerated for safety reasons. Further, the police were not attempting to use the Criminal Code to enforce provincial legislation. While fines were provided, no power of arrest was for a lack of insurance. The Criminal Code charges were for frustrating towing, and, in the second incident, for frustrating seizing the plate: R. v. Waugh, 2010 CarswellOnt 576  (Ont. C.A.).