Stay of proceedings for abusive police conduct

R. v. Bellusci, 2012 SCC 44 deals with a stay of prosecution because of abusive police conduct. The Court, albeit restricting its position to rare cases, upheld such a stay. Some might argue that abusive police conduct unrelated to the charge itself (in this case the conduct was related to the offence directly) ought never to ground a stay - such argument did not find favor with the Court:

[31]   In short, the trial judge in this case carefully and correctly considered all the relevant principles. He assessed the gravity of the prejudice and explained why he thought alternative remedies were inadequate. He did not misdirect himself on the applicable law or commit a reviewable error of fact. Nor was his exercise of discretion to grant a stay of proceedings “so clearly wrong as to amount to an injustice” (Regan, supra). My conclusion in this regard relates exclusively to the circumstances of the present matter. In fairness to the trial judge, however, I note that other judges have considered a stay of proceedings to be a proportionate remedy for mistreatment suffered at the hands of law enforcement officers: R. v. Walcott (2008), 57 C.R. (6th) 223 (Ont. S.C.J.); R. v. Maskell, 2011 ABPC 176, 512 A.R. 372; R. v. Jackson, 2011 ONCJ 228, 235 C.R.R. (2d) 289; R. v. Mohmedi, 2009 ONCJ 533, 72 C.R. (6th) 345; R. v. J.W., 2006 ABPC 216, 398 A.R. 374; R. v. R.L.F., 2005 ABPC 28, 373 A.R. 114; R. v. Wiscombe and Tenenbein, 2003 BCPC 418 (CanLII); R. v. Murphy (2001), 29 M.V.R. (4th) 50 (Sask. Prov. Ct.); Spannier v. R.,1996 CanLII 978 (B.C.S.C.).^[