Towle, jailed for 10 years after killing six teenagers in a hit-run in 2006, faced sentencing in Bendigo Magistrates Court on Tuesday after pleading guilty to two driving charges.
The 53-year-old admitted he was unlicensed when he was caught driving a Holden Commodore along the Calder Highway in central Victoria in September 2024.
Towle tried to swap places with his passenger when pulled over by police but eventually conceded he was the one behind the wheel.
He also returned a positive drug test result for methamphetamine.Â
In March, Towle's lawyer Walinda Bonne told the court he had tried to organise alternative transport for his mother's surprise birthday party but it fell through.
It was conceded Towle had a "chequered, lengthy and relevant" criminal history but he was making efforts to change, she said.
Police argued a jail sentence was required to prevent him from "deliberately flouting the law", pointing to his 12 prior convictions of driving while unlicensed or disqualified.
But Magistrate Megan Aumair ordered Towle be assessed for a community corrections order after Ms Bonne provided proof he was engaging with drug, counselling and cultural services.
"I don't think there's ... any physical reason why you can't do any community work focusing on drug treatment and other rehabilitative aspects of the order," the magistrate said on Tuesday.
"This, I think, will ensure that we don't see you again in court or fall foul of the justice system."
Towle's licence was cancelled and he was disqualified from driving for 18 months when his sentence was deferred in March.
In 2008, Towle was sentenced to 10 years' jail after he drove into a group of 13 teenagers in Mildura in February 2006.
The crash took the lives of Shane Hirst, 16, his 17-year-old sister Abby Hirst, Stevie-Lee Weight, 15, and Cassandra Manners, Cory Dowling and Josephine Calvi - all aged 16.
Towle fled the scene, leaving his injured preschool-age son in the car, before later handing himself in to police.
He was released from prison in June 2013 on good behaviour with strict conditions but was re-jailed in September 2015 for an unspecified parole breach.
Towle was released again in May 2017 after his sentence was cut by eight months and a successful parole application.
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