R v Pilon, 2018 ONCA 959 (Hourigan):

[27] Notwithstanding the broad statement in para. 102 of Golden, that exigent circumstances are limited to safety concerns, and the absence of case law considering preservation of evidence as an exigent circumstance justifying a field strip search, it is at least arguable that the Supreme Court in Golden left open the possibility that the need to preserve evidence could qualify as exigent circumstances that permit a field search. For the purposes of my analysis below of the two strip searches in this case, I am prepared to assume that the preservation of evidence can qualify as exigent circumstances. I do this because, as will be explained, in the present case I am not satisfied that there was an exigent need to preserve evidence. I leave open the possibility that another case might provide a factual matrix that presents very serious and immediate concerns about the preservation of evidence such that there is an urgent and necessary need to conduct a strip search in the field.