During a criminal trial arising from a fatal motor vehicle collision, the defence challenged the admissibility of expert accident reconstruction evidence tendered by the Crown.
The proposed expert, a police collision reconstruction officer, was questioned on both his qualifications and whether his speed‑calculation methodology constituted novel scientific evidence.
Applying the admissibility framework from R. v. Mohan, the court held the witness possessed sufficient specialized knowledge through training and extensive investigative experience.
The court further held that the use of an “in‑line momentum” formula for speed calculation was an accepted technique within accident reconstruction and not novel science requiring special scrutiny.
The expert evidence was therefore admitted, with any methodological concerns affecting weight rather than admissibility.
