What is the current state of the law on access to counsel under s. 223(1) of the Canadian Bill of Rights?

I turn now to the judgment of Laskin J. in Brownridge v. the Queen, 1972 CanLII 17 (SCC), [1972] S.C.R. 926, 18 C.R.N.S. 308, 7 C.C.C. (2d) 417 at 435, 28 D.L.R. (3d) 1: “If there is to be a preference, I think that the language of the Canadian Bill of Rights requires that it be accorded to the guarantees of that enactment. Section 2 enjoins a construction and application of a law of Canada, in this case s. 233, that would abridge or infringe any of the rights or freedoms recognized in the Canadian Bill of Rights; and one of these is the right of an arrested or detained person to retain and instruct counsel without delay. I must note however that in particularizing certain rights, s. 2 speaks in terms of depriving an arrested or detained person of the right to retain and instruct counsel without delay. I do not see that this weakens the injunction against abridgment or infringement. “On this view, it does not lie with an arresting police officer to determine in his discretion or on a superior’s instructions whether or when to permit an arrested person to contact his counsel. The right to retain and instruct counsel without delay can only have meaning to an arrested or detained person if it is taken as raising a correlative obligation upon the police authorities to facilitate contact with counsel. This means allowing him upon his request to use the telephone for that purpose if one is available. I am not concerned in this case with determining how many calls must be permitted. Here, on the facts, the accused was prevented from making even one. I am content to say for the purposes of this case that the accused’s right under s. 2(c) (ii) would have been sufficiently recognized if, having been permitted to telephone, he had reached his counsel and had spoken with him over the telephone. I would not construe the right given by s. 2(c) (ii) when invoked by an accused upon whom a demand is made under s. 223(1), as entitling him to insist on the personal attendance of his counsel if he can reach him by telephone. I refrain from enlarging on the matters mentioned in this paragraph of my reasons because it is better that this be done when particular cases call for it.” (The italics are mine.)