Fairness of the trial is not the only consideration. In some cases, where the fairness of the trial was not in issue, evidence has nevertheless been excluded where the Charter violation was a serious one: R v. Greffe (1990), 1990 CanLII 143 (SCC), 55 C.C.C. (3d) 161,  1 S.C.R. 755, 75 C.R. (3d) 257.
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