What is the impact of unlawful electronic surveillance on the privacy interests of the accused?

Unlawful electronic surveillance necessarily has a serious deleterious effect on the Charter-protected privacy interests of the accused. Surreptitious electronic surveillance by the state is one of the most severe intrusions into the sphere of personal privacy. As La Forest J. remarked in Duarte, at para. 19, “One can scarcely imagine a state activity more dangerous to individual privacy than electronic surveillance”. La Forest J. also adopted (at para. 22) the comment by Douglas J. in United States v. White, that “electronic surveillance is the greatest leveller of human privacy ever known.”