Can a certificate of analysis be used to prove that a bottle contains liquor?

Saskatchewan, Canada


The following excerpt is from R. v. Sinclair, 1953 CanLII 165 (SK PC):

I am not suggesting that a certificate of analysis is always necessary to prove liquor. It is possible that this might be done by other means—Rex v. McPherson (1915) 1915 CanLII 159 (SK CA), 9 WWR 613, 8 Sask LR 412, 33 WLR 21, 25 CCC 62, but I think it would be dangerous to find that bottles contained liquor within the meaning of The Liquor Act from the label only.

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