The standard of proof required to establish that an indictable offence has been committed is not any higher than the standard of proof generally required in civil proceedings, being on a preponderance of evidence basis: Hayward, supra, at p. 355; Frey v. Fedoruk, 1950 CanLII 24 (SCC), [1950] 3 D.L.R. 513, 97 C.C.C. 1, [1950] S.C.R. 517.
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