The criminal record of a suspect, by itself, cannot provide reasonable grounds for a search. But if the suspect was previously convicted of an offence which is the same as or similar to the offence being investigated, the record is relevant and admissible on the issue of whether reasonable and probable grounds existed to justify an arrest and search. If a conviction is recent, it will carry more weight than a conviction that is several years old. If there is more than one previous conviction for the same or a similar offence, that will increase the weight that may be given to the criminal record, on this issue. See Regina v. Debot for the leading discussion of this issue.
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