Towle, who was jailed for 10 years after killing six teenagers in a hit-run in 2006, pleaded guilty in Bendigo Magistrates Court on Thursday to two new 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.
When police pulled him over, he tried to swap places with his passenger but eventually conceded he was the one behind the wheel.
Towle also returned a positive drug test result for methamphetamine.
His lawyer Walinda Bonne said Towle had tried to organise alternative transport for his mother's surprise birthday party but it fell through.
He accepted he made a poor decision to drive the car, Ms Bonne said.
It was conceded Towle had a "chequered, lengthy and relevant" criminal history but he was making efforts to change, the lawyer said.
That included engaging in counselling for his drug issues and connecting with Indigenous elders in Bendigo to find meaningful employment.
Ms Bonne urged Magistrate Megan Aumair to consider a community corrections order instead of sending Towle to prison.
But police prosecutor Dave Somerton said jail was the only way to stop Towle from "deliberately flouting the law".
He pointed to his 12 prior convictions of driving while unlicensed or disqualified.
"I don't want to be on the other side of the road with Mr Towle coming towards me," the sergeant said.
"He has to understand there is a price to pay."
Ms Aumair deferred Towle's sentence to April so he could prove he was committed to engaging with his counselling and drug treatment.
"Show me ... that you are fair dinkum about this," Ms Aumair told Towle.
"Continue to drive and flout the law and you will go to jail."
She cancelled his licence ahead of his sentence and disqualified him from driving for 18 months.
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.
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