Under what circumstances will the police need to obtain a companion authorization to search a person's home?

To the extent that it speaks to companion authorizations issued by a justice, I agree with the reasoning offered by Nordheimer J. in R v. Lucas, [2009] O.J. No. 5333 (S.C.) at para. 28: In this case, the concern about the police entering a dwelling house to effect a arrest entirely on their own initiative and without satisfying a judge that there are reasonable grounds to do so does not arise due to the fact that the police had already satisfied a judge that they had reasonable grounds to enter the dwelling house for the purposes of the search. To require the police, in such circumstances, to also obtain a companion authorization to enter the same house to arrest a person that they expect to find in that house would be redundant. It would not advance the fundamental principle that is at stake, namely, the protection of the privacy rights of the individual. Once a judge has been satisfied that the police have good and sufficient reason to enter a person's home, that core privacy issue has been resolved adversely to the person. Requiring additional authorizations to overcome those same privacy interests would be superfluous.