R v McKinnon, 2018 ONSC 4781 (Gareau): [76] Section 162(2) of the Criminal Code defines the term “visual recording” to include photographic. Regrettably, there is no definition of what is intended by the phrase “surreptitiously” in the Criminal Code. The dictionary’s definition of surreptitious is “covert or clandestine”, or, in other words, something that is done secretly. In the case Read more...