Appendix I: Reasonable Belief

• Author: Steve Coughlan/Glen Luther
• Profession: Professor, Schulich School of Law, Dalhousie University/Associate Professor, College of Law, Saskatchewan
• Pages: 306-313

306

APPEN DIX I

REASONABLE BELIEF

Reasonable Grounds for Arrest Made Out

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

mation from an informant concerning a future dr ug deal. The inform-

ant 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 b een received directly from one of the parties to

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

names of the parties to the offence. The police e stablished v isual sur-

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

police was observed a long with persons enter ing/exiting t he premises;

Cst. G, by radio to an off-site off‌icer (Sgt. B), conf‌irmed that the accused

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

off‌icers to intercept and search the vehicle. On these facts Cst. B had

reasonable and probable grounds to believe that the accused had drugs

in hi s possession, de spite relia nce on hearsay from other off‌icers. An

off‌icer instructed to carr y out a search by another off‌icer i s entitled to

assume that the off‌icer orderi ng the search has re asonable grounds.

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

went beyond mere rumour; the informant was reliable and not paid nor

facing charges; and the police sur veillance corroborated t he inform a-

tion received.

R. v. Wong, [1990] 3 S.C.R. 36 (obiter conclusion on reasonable grounds

for arrest for unlawf ul gaming): The police entered a recently vacated