What is the test for strip searches under s. 8 of the Charter?

The mere possibility that an individual may be concealing drugs on his or her person is not sufficient to justify a strip search of that person: Golden, at para. 94. Further, strip searches conducted as a matter of routine policy, even if executed in a reasonable manner, are not reasonable within s. 8 of the Charter. Compelling reasons, rooted in the circumstances of the arrest, are required to render a strip search reasonable, even where the execution is flawless: Golden, at para. 95. Rote application of police policy is anathema to the case-specific, fact-sensitive consideration mandated by Hunter v. Southam Inc.