On the first criterion, that of reliability and contemporaneousness, is this statement made by a police officer as part of an internal investigation?
Canada (Federal), Canada
The following excerpt is from Hibbert v. Canada, 2000 CanLII 15768 (FC):
On the second criterion, that of reliability, it appears that the officer"s statement was made by a person in charge of the investigation who did not have any personal interest and who was following an internal procedure. Furthermore, this statement was made right after the events. The factor of contemporaneousness is adequately met. Reed J., in Kelly v. The Queen (1994), 80 F.T.R. 1, mentioned the importance of this factor, at p. 2:
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