Vetrovec warning not required in Judge alone trial

R. v. Snyder, 2011 ONCA 445 is a useful source for the (fairly obvious) principle that a judge sitting alone does not have to warning themselves of the dangers of unsavory witnesses. The Court writes:

(b) Did the trial judge give himself an adequate "Vetrovec" warning?

[23] The appellant submits that because the trial judge expressly adverted to some of the reasons for approaching the evidence of Burgess and Doucette with caution, it must be assumed that he did not bear in mind the other reasons for approaching their evidence cautiously. This argument assumes that a trial judge must, in his or her reasons, address "Vetrovec" concerns in much the same manner as the trial judge does in his or her instructions to a jury.

[24] There is no need to import the requirement of a "Vetrovec" caution designed to alert juries to the danger of relying on the evidence of certain witnesses into a trial judge's reasons for judgment. Judges know the risks inherent in relying on witnesses like Burgess and Doucette. It would be pure formalism to require judges to articulate those dangers in their reasons.