The accused was stopped for stunt driving and arrested under the Highway Traffic Act.
After the accused failed to produce vehicle registration and insurance, the officer searched the vehicle, including a satchel in the back seat, and found 242 grams of cocaine.
The accused brought a Charter application alleging arbitrary detention and unreasonable search and seizure.
The court dismissed the application, finding the detention was justified and the search was a valid search incident to arrest for the purpose of locating required documentation.
The court also held that even if there were breaches, the evidence would not be excluded under s. 24(2).