In Ontario Secondary School Teachers’ Federation, District 9 v. Greater Essex County District School Board (Bondy Grievance),  O.L.A.A. No. 561, a labour arbitrator concluded that the strip search of 16 high school students exceeded the established parameters for such searches laid down in R. v. M.(M.R.), 1998 CanLII 770 (SCC),  3 S.C.R. 393 which requires searches to be carried out in a reasonable and sensitive manner and be minimally intrusive in light of all of the surrounding circumstances.
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