police. Again, the violation was justified under section 1. Investigative detention In R. v. Simpson, the Ontario Court of Appeal found that police could not use their traffic stop powers as a pretext to detain an individual in the context of a criminal investigation. Simpson confirms that the power to detain for investigative purposes can only be exercised where there is "a constellation of objectively discernible facts which give the detaining officer reasonable cause to suspect that the detainee is criminally implicated in the activity under investigation." This test was upheld and expanded upon by the Supreme Court of Canada in R. v. Mann. Security certificates In Charkaoui v. Canada (Citizenship and Immigration), the Supreme Court ruled that the Canada's security certificate regime, which enabled the pretrial detention of those suspected of posing a threat to national security, constituted arbitrary detention within the meaning of Section 9 of the Charter. Notes External links Section 9 Charter Digest at canlii.org Fundamental Freedoms: The Charter of Rights and Freedoms – Charter of Rights website with video, audio and the Charter in over 20 languages Section 09