What is the current state of the law on fear under section 810 of the Criminal Code?

[188] As stated by Laskin J.A. in Regina et.al. v. Budreo, supra., “fear alone connotes a state of belief or an apprehension that a future event, thought to be undesirable, may or will occur”. Furthermore, in Regina v. Soungie, supra., in describing the principles relative to the subjective element of an application under section 810 of the Criminal Code, Allen J. stated, in part, as follows: The first requirement is that the applicant have such a honest and actual fear. The absence of proof that the applicant has such will mean there is no basis upon which a recognizance can be issued. Obviously, it is preferable that the applicant articulate the fear but the failure to articulate does not necessarily mean the fear is not present. The surrounding circumstances can give rise to an inference that the fear exists. …