Appendix I: Reasonable Belief

• Author: Steve Coughlan/Glen Luther
• Profession: Professor, Schulich School of Law, Dalhousie University/Associate Professor, College of Law, University of Saskatchewan
• Pages: 392-402

392

APPEN DIX I

R EA SONABLE BELIEF

Reasonable Grounds for Arrest Made Out

R v Debot, [1989] 2 SCR 1140: The police received conf‌idential infor-

mation from an informant concerning a future drug deal. The informant

had previously provided useful information to the police (Cst. G) and

was considered by the police to be reliable. The informant provided

details said to have been received directly from one of the parties to the

drug transaction indicating the date, time, location, type of drug, and

names of the parties to the oence. The police established visual sur-

veillance of the anticipated site of the drug deal; a vehicle known to the

police was observed along with persons entering/exiting the premises;

and Cst. G, by radio to an o-site ocer (Sgt. B), conf‌irmed that the

accused was the registered owner of the vehicle. Sgt. B then instructed

other ocers to intercept and search the vehicle. On these facts, Cst. B

had reasonable and probable grounds to believe that the accused had

drugs in his possession, despite reliance on hearsay from other ocers.

An ocer instructed to carry out a search by another ocer is entitled

to assume that the ocer ordering the search has reasonable grounds.

The tip provided by the informant was compelling and detailed: it

went beyond mere rumour; the informant was reliable and not paid or

facing charges; and the police surveillance corroborated the information

received.

R v Wong, [1990] 3 SCR 36 (obiter conclusion on reasonable grounds

for arrest for unlawful gaming): The police entered a recently vacated