Wednesday, September 29, 2010

Voluntariness and warning on detention

R. v. Brown, 2010 ONCA 622, released today online, has a useful quotation about the need to ensure a warning is given when an accused is detained:

[10]         Where, as here, the accused was detained, whether or not formally arrested and charged, the presence or absence of a caution is a factor, and in many cases an important factor, in answering the ultimate question of voluntariness.  This well-established principle was reiterated by Charron J. in

R. v. Singh, [2007] 3 S.C.R. 405 at paras. 31 and 33.  The trial judge's erroneous finding that a partial caution had been given was a legal error that had a direct bearing upon the issue of voluntariness.

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