Before Duarte v. The Queen, 1990 CanLII 150 (SCC), [1990] 1 S.C.R. 30, 53 C.C.C. (3d) 1, interception by the state of communications between two persons, one of whom consented to the interception (“participant interceptions”), did not require prior authorization under the Criminal Code. Amendments were made to the Code as a result of that decision.
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