Robert Delorme.

Oui, merci.

Paul Sukha.

Sukha.Thank you, and good afternoon, Chief Justice and Justices.

As a warrantless search of individuals who are not necessarily arrested or detained, safety searches are exceptional police powers.

In this context, the Criminal Lawyers Association encourages the court to affirm the reasonable grounds to believe standard, but I'm gonna focus my submissions today on the issue of uncertainty that has come up and confusion that's been discussed throughout the hearing, and ask the court to take the opportunity to set clear standards to guide the conduct of these exceptional circumstance- of these exceptional searches as it has done in cases such as Golden, Saeed, and Fearon.

The first guideline that we suggest, which has been discussed, is that a safety search is only permitted where there is an imminent threat to safety, and this has been touched on including by the Attorney General of Ontario.

And we agree that this must be connected to the Waterfield standard and the question of whether or not a safety search is reasonably necessary in the circumstances.