Le camouflage d'une infraction commise ou les tentatives de la camoufler constituent une circonstance aggravante au niveau de la détermination de la peine

R. c. Chicoine, 2012 QCCA 1621 (CanLII)

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[86] Le camouflage d'une infraction commise ou les tentatives de la camoufler constituent une circonstance aggravante dont le juge devait tenir compte :

Planning after the offence, to avoid detection, is no different. In Northern Electric Co. Ltd., McRuer C.J.H.C. analyzed the method used by the companies and concluded that:

…the parties involved were making it as difficult as possible for the proper authorities to ascertain exactly what was done and who was responsible for doing it, so that it would be very difficult eventually to succeed in a prosecution….

Having all that in mind, I cannot bring myself to have the same sympathy for these convicted companies as I have for the Queen's subject who is charged with an ordinary criminal offence and is brought to the Court for justice.

The same approach can be seen in sentencing individuals who attempt to "cover up" their crimes. The principle is as old as Coke "omnia delicata in aperto levioria sunt" (all crimes are less grave when done openly).
[87] Comme l'écrit l'auteur Clayton C. Ruby, de tels gestes constituent au surplus de sérieux indices de caractère et d'attitude générale du contrevenant :

The behaviour of the offender is usually a better indication of his character and attitude than what he or his counsel say about him