The concept of “reasonable grounds to believe” imports a measure of uncertainty. In Descôteaux v. Mierzwinski, 1982 CanLII 22 (SCC), [1982] 1 S.C.R. 860, 70 C.C.C. (2d) 385, Lamer J. (as he then was) noted that searches are an investigative tool, and it may not be possible to determine the probative value of something before the investigation is complete.
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