

R v. Devloo, [2020] MJ No. 2 Credibility of a Civilian Agent
Author: J McRae Where the Crown has employed the use of a civilian agent to procure evidence from a criminal enterprise that agent’s credibility becomes integral to the credibility of any evidence they procure. This is especially true when the agent has some aspect of their person, such as a criminal history, which might indicate some level of untrustworthiness. In this case the civilian agent is the sole source of the evidence produced against the appellant, and the agent’s




