R v Collins (1987)

The Collins test for section 24(2) was developed for determining if the administration of justice was brought into disrepute by the inclusion of the evidence.

The Royal Canadian Mounted Police Drug Squad in Vancouver had Ruby Collins under surveillance as part of an investigation into a "heroin problem".

One of the officers approached her in a local pub, told her that he was a police officer, and then grabbed her by the throat and in the process dragged her down to the floor in what is known as a "throat hold" used to prevent suspects from swallowing drug filled balloons.

At the voir dire, Crown counsel sought to justify the search under what was then section 10 of the Narcotics Control Act (NCA).

Lamer J. concluded that, since the Crown had not established that the search had met the requirements of section 10 of the Narcotics Control Act, it was not authorized by law.

The second point of analysis examines whether admission of the evidence would implicitly condone the illegal practices of the police.

The courts compare the seriousness of the breach and the fairness of the trial against the importance of the evidence in the Crown's case and the overall.