What is the current narrow approach to the issue of coerced confessions?

British Columbia, Canada


The following excerpt is from R. v Blackmore, 2017 BCSC 2682 (CanLII):

The narrow approach, originating in Ibrahim v. The King, [1914] A.C. 599 (P.C.) and adopted in Canada in cases such as Boudreau v. The King, 1949 CanLII 26 (SCC), [1949] S.C.R. 262, gave the accused what was viewed as only a negative right; that is, the right not to be tortured or coerced into confessing by threats or promises. Confessions were excluded only where authorities held out explicit threats or made promises to the accused.

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