What is the test for naming in an affidavit under section 185(1)(e) of the Communications Privacy Act?

Section 185(1)(e) requires the affidavit to include "the names, addresses and occupations, if known, of all persons, the [page224] interception of whose private communications there are reasonable grounds to believe may assist the investigation of the offence". The test for naming involves two components. The first has to do with identity and the second with investigative assistance. The requirements are cumulative. If a person meets both of these criteria at the time the authorization is sought, he or she is a "known" person. If it is later proposed to adduce that person's intercepted private communications as evidence, that person must be described as a "known" person in the authorization: R v. Chesson, 1988 CanLII 54 (SCC), [1988] 2 S.C.R. 148, [1988] S.C.J. No. 70, at p. 164 S.C.R.