Good question! I heard of retailers refusing the sale when there's no customer activation. On the other hand I don't see why not so I'm on eighther side of the fence on that one. But if you can keep in mind the cell phones comes locked to Koodo other then the Nexus 4,5 (cell phones). Which means you'd have to use it on the Koodo network for minmum 90 days to get the phone unlocked.
Or you can buy a prepaid phone and give it to your mom.
(You don't need to do a credit check )
If your mother decided to activate postpaid(monthly) plan afterwards, she just needs to do a credit check and get a sim card for the postpaid plan later( she can pick any plan she want) .