Does a police officer’s template/notes constitute "canned evidence"?

Ontario, Canada


The following excerpt is from R. v. Law, 2013 ONCJ 533 (CanLII):

[39] The agent for the applicant’s representative herein submits that the principles enunciated in Regina v. Murphy, supra, apply to the case at bar. She argues that the pre-conceived statements and assertions set out in Officer Bendiks’ template/notes, which do not provide for any variation to conform with his actual observations at the material time, constitute “canned evidence” and that the particular statements cannot be considered to be sufficiently reliable so as to constitute full and adequate disclosure of the anticipated testimony of the said police officer.

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