What is the test for a search without a warrant under the Criminal Code of Canada?

Cloutier v. Langlois, 1990 CanLII 122 (SCC), [1990] 1 S.C.R. 158 establishes that the common law right to search without warrant, that is strictly incidental to an arrest, is a lawful search and an exception to the reasonable search requirement. Such a search does not require reasonable and probable grounds beyond those required for the arrest because the arrest itself provides the grounds for the search. But there are three limitations on the power to search incident to arrest: i) A search must not be conducted if the police are satisfied that the law can safely be applied without a search; ii) The search must be for a valid objective in pursuit of the ends of criminal justice, such as the discovery of something that may act as evidence against the accused; iii) The search must not be conducted in an abusive fashion.