What is the current state of the law on arrests in a dwelling house?

23. In arguing that the police conduct in the present case did not violate the Charter, the respondent relied heavily on the lawfulness of the arrest. Since the arrest was lawful, the argument runs, the search and seizures incidental to the arrest were lawful and complied with the Charter according to Cloutier v. Langlois, 1990 CanLII 122 (SCC), [1990] 1 S.C.R. 158. In what follows, I will consider first whether the arrest was lawful under the common law rules relating to arrests in a dwelling house. Subsequently, I will consider whether the common law rules are no longer appropriate in light of the Charter. I conclude that the arrest was unlawful under either the rules of the common law or the Charter. The Pre-Charter Law of Arrests in Dwelling Houses