In R v. Parks [2005] O.J.No.937 at para. 37 (Sup. Crt.) Hill J. examined the requirement of a voir dire in the context of an utterance made to a police officer and stated that not every failure to conduct a confessional voir dire will amount to procedural error automatically negating a verdict and that a reviewing court must determine whether the error occasioned a substantial wrong or miscarriage of justice.
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