What is the test for arrest under section 495(1)(a) of the Criminal Code?

40. In his factum, he submitted that where a police officer arrests an individual without a warrant pursuant to section 495(1)(a) of the Criminal Code, the officer must, on reasonable and probable grounds, believe that the person has committed or is about to commit an indictable offence. The grounds must be reasonable on an objective and subjective basis: see Regina v. Storey (1990) 1990 CanLII 125 (SCC), 53 C.C.C. (3d) 316 at pp. 323-234 (S.C.C.): In summary then, the Criminal Code requires that an arresting officer must subjectively have reasonable and probable grounds on which to base the arrest. Those grounds must, in addition, be justifiable from an objective point of view. That is to say, a reasonable person placed in the position of the officer must be able to conclude that there were indeed reasonable and probable grounds for the arrest. On the other hand, the police need not demonstrate anything more than reasonable and probable grounds. Specifically they are not required to establish a prima facie case for conviction before making the arrest.