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common law police powers generated at the 

Early cases decided by appeal courts centred on issues related to motor vehicles and roadside stops. As the case law grew in this area, courts such as the Ontario Court of Appeal decided cases such as R v Simpson which deliberated on whether police had the power of investigatory detention and what type of evidentiary standard of proof is required to justify the detention. This particular decision paved the way for cases such as R v Mann which built on the ruling in R v Simpson. 


Appeal court level rulings have generated 34 new police powers since 1985

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