What are the limits to a search incidental to an arrest?

I would add only that I respectfully disagree with my colleagues’ contention that none of the limits to a search incidental to an arrest articulated by L’Heureux-Dubé J. in Cloutier v. Langlois, 1990 CanLII 122 (SCC), [1990] 1 S.C.R. 158 is in issue in this case. Recall that L’Heureux-Dubé J. stated at para. 60: “1. This power does not impose a duty. The police have some discretion in conducting the search. Where they are satisfied that the law can be effectively and safely applied without a search, the police may see fit not to conduct a search. They must be in a position to assess the circumstances of each case so as to determine whether a search meets the underlying objectives.”