While the necessity for a police officer to make accurate, comprehensive and contemporaneous notes cannot be understated (Wood v. Schaeffer, 2013 SCC 71), as a general rule, perceived, acknowledged or found deficiencies or omissions from a police officer’s notes relating to a particular transaction may, or may not, hold any significance depending on specific factual context. An absent note may impact on the weight to be afforded an officer’s evidence. Automatic rejection of the officer’s evidence as a discipline sanction is inappropriate. The significance of an omitted notational reference will depend upon such factors as the number of gaps, the nature of an omission in terms of the importance of the fact in question, the explanation for the omission, the overall degree of completeness of the notes, the length of the interval between the making of the notes and the delivery of oral testimony, and the existence of confirmation for the missing note. [Emphasis added in original]
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