What is the legal test for probable searches in the context of Section 487.05 of the Criminal Code?

Section 487.05 requires the authorizing member of the judiciary to be satisfied by information on oath that there are reasonable grounds to believe a number of matters including that the person who is the proposed subject was a party to the offence. As pointed out by Sopinka J. in Baron v. Canada (1993), 1993 CanLII 154 (SCC), 13 C.R.R. (2d) 65 at pp. 85-86, [1993] S.C.R. 416 at pp. 446-47, nothing turns on the omission of the word “probable”. Thus, the standard used is one of “reasonable grounds” which, as Dickson J. pointed out, is the appropriate requirement as the threshold for subordinating the expectation of privacy to the needs of law enforcement. It is true that His Lordship went on to say that a different standard might be appropriate when the proposed search threatens the person’s bodily integrity. Counsel suggests that words such as “high degree of probability” or “cogent and compelling” should have been used.