In what circumstances will a police officer be permitted to enter a store to search for illegal betting on horse races and football games?

In People v. Cognetta and Grecco the officer stationed himself outside a store, from whthin which he heard telephone conversations indicating bets were being placed on horse races and football games. The store door was closed and locked. The officer climbed through the transom and entered the store, observed the defendants and placed them under arrest. This evidence was insufficient to authorize a search as an incident to a lawful arrest, since before entering the premises the officer did not know the identities of those to be charged or arrested. (See Johnson v. United States, supra.)