R v Figiola – 2018 ONCA 578 (Doherty JA):

[68] As I understand the thrust of this submission, the appellant contends that cross-examination under s. 9(1) of Crown witnesses is limited to situations in which the inconsistent evidence is unexpected and/or there is some real likelihood that cross-examination will cause the witness to adopt the earlier inconsistent statement.

[69] The law is firmly against this submission: see Dooley, at para. 161.