What is the current state of the law on voyeurism?

In considering this charge, I am mindful of the comments of Feldman J.A. in R v. Jarvis and, in particular, her remarks at para. 24 of that judgment, which bear repeating here: The sexual aspect of the offence arises from one or two sources (and in any given case, both may be operative): the purpose for which the observation is made (e.g. sexual arousal of the voyeur) or, alternatively, the nature of the subject observed (e.g. viewing or recording the victim’s sexual organs or the victim engaged in explicit sexual activity.) The policy justification for prohibiting voyeurism in this context is that it prevents a private citizen from sexually exploiting another private citizen. The sexual exploitation occurs the moment that the voyeur observes or records the victim, even if the victim is not aware of it. [Emphasis in original.]