What is the test for reasonable and probable grounds for a search incident to arrest?

Ontario, Canada


The following excerpt is from R. v. Bryan, 2008 CanLII 2595 (ON SC):

A search incident to arrest does not require reasonable and probable grounds beyond the grounds that were sufficient to support the lawfulness of the arrest itself: Cloutier v. Langlois, 1990 CanLII 122 (SCC), [1990] 1 S.C.R. 158.

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