What is the test for failing to surrender a permit?

[88] In light of the fact that there is conflicting evidence before me as to the element of whether the defendant actually surrendered the permit for the subject motor vehicle to the investigating police officer, I must analyze the totality of the evidence in accordance with the principles set out in Regina v. W.(D.), supra. In particular, I am required to ask myself whether the defendant’s exculpatory evidence considered in the context of the evidence as a whole, raises a reasonable doubt as to her guilt of the charge of fail to surrender permit for motor vehicle.