This is a case comment on R v Ibrahim, 2021 MBCA 12.

The Manitoba Court of Appeal notes in this case that there are no categorical limits on the spatial and temporal connection between the location of an arrest and the areas searched. They quote R v Fearon, 2014 SCC 77, at para 13 to the effect that "the permissible scope of searches incident to arrest will be affected by the particular circumstances of the particular arrest. The courts will rarely be able to establish any categorical limit applicable to all arrests and all purposes incidental to them."

There is no question that that is an accurate depiction of the current state of the law. Nonetheless, there is good reason for dissatisfaction with that current state.