Lex Pundit
CriminalSettled test

Excluding evidence obtained in breach of the Charter

Evidence obtained in breach of a Charter right is excluded where admitting it would bring the administration of justice into disrepute.

Position current as of July 2026

Current position

Section 24(2) of the Charter does not exclude unlawfully obtained evidence automatically. A court asks whether, having regard to all the circumstances, admitting the evidence would bring the administration of justice into disrepute.

The inquiry weighs three lines: the seriousness of the Charter-infringing state conduct, the impact of the breach on the accused's protected interests, and society's interest in an adjudication on the merits. The focus is the long-term repute of the justice system, not the outcome of the individual case.

Governing authority
R v Grant
2009 SCC 32

Grant sets the current three-line inquiry under section 24(2).

Key cases
Supreme Court of Canada
R v Grant
2009 SCC 32 · Jul 17, 2009

The Court restated when a person is “detained” for Charter purposes and set a three-part framework for deciding whether evidence obtained in breach of the Charter should be excluded under section 24(2), focused on the long-term repute of the justice system.

How the law evolved
1982
Charter, s. 24(2)Statute
A remedy for excluding evidence enters the constitution, without a fixed test.
2009
R v GrantLeading case
2009 SCC 32
A three-line framework replaces the earlier approach and redefines detention.
Today
Applied line by line
Courts weigh state conduct, impact, and society's interest in a trial on the merits.