The standard of waiver of the right to counsel is high. Valid waivers of the informational component of section 10(b) are rare. If the circumstances reveal that a detainee does not understand, then the authorities are required to take additional steps to ensure that the detainee comprehends: Regina v. Bartle, 1994 CanLII 64 (SCC), [1994] S.C.J. No. 74, at paragraphs 38 and 39.
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