In the vase majority of situations involving a warrantless entry, announcement, at an absolute minimum, would be required. However, as in situations involving entry to effect an arrest, announcement prior to entry is a pre-condition "except in exigent circumstances" — Eccles v. Bourque (1974), 1974 CanLII 191 (SCC), 19 C.C.C. (2d) 129 (S.C.C.) at 133.
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