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Section 180 of the HTA prescribes littering on a highway is a prohibited violation as follows, Every person who throws or deposits or causes to be deposited any glass, nails, tacks or scraps of metal or any rubbish, refuse, waste or litter upon, along or adjacent to a highway, except in receptacles provided for the purpose, is guilty of the offence of littering the highway. 5 A peace officer simply would need to observe you throw anything (such as a cigarette butt) to be construed as rubbish, waste, or litter on the roadway