What is the case law on surreptitious recording of telephone conversations in a family law case?

First, I agree with counsel for the applicant that there are public policy considerations that weigh against admitting the impugned evidence. I have previously commented[3] on the practice of making surreptitious recordings by parties in family law cases – which practice has often been to referred as “odious” and “repugnant” by the courts – and have expressed my agreement with the observations of Sherr J. in Hameed v. Hameed that the surreptitious recording of telephone conversations by parties in family law cases should be strongly discouraged by the courts.