R. v. Brown, 2013 ONCA
128 holds that one
unsavoury witness can confirm the testimony of another. Put otherwise, two
Vetrovec witnesses can confirm
each other:
[12] We
disagree. As expressed by this court in R. v. Drabinsky, 2011 ONCA
582, 107 O.R. (3d) 595 at para. 140:
There is, however, no
prohibition against the evidence of one Vetrovec witness confirming the evidence of
another Vetrovec witness.... The question is not whether the
witness is him or herself a Vetrovec witness, but whether the evidence of each
witness is sufficiently independent of the evidence of the other to provide
confirmation.
[13] Recently, in R. v. Pelletier, 2012 ONCA
566, 295 O.A.C. 200 at para. 69, Watt J.A. stated that “at least in the absence
of evidence of collusion or collaboration, the evidence of one unsavoury witness
can confirm the testimony of another.”
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