[ i]nformation could be relied upon by the issuing [j]ustice”. As the
SCAJ observed, if verification for accuracy were required, “
hearsay evidence would never be sufficient to support the issuance of
a search warrant”.
 I agree.
The trial judge’s errors
 As the SCAJ pointed out [at para. 97], “verified as to
accuracy” is not consistent with how the standard is usually
described in judicial authorities. The terms usually used are
“credibly-based probability”, “reasonable probability” or “
reasonable belief”. Section 487(1) of the Criminal Code authorizes
a justice to issue a warrant if there are “reasonable grounds to
 Certainly, it must be considered whether the information
provided by a third-party source outside the police is compelling,
from a credible source, and corroborated. However, that does not
change the standard of “reasonable belief”. The SCAJ pointed out
[at para. 82] that a tip or information that “comes from a source
which is generally credible and reliable . . . can provide some evidence which an issuing justice could rely on to issue a search warrant”. I agree. The standard is reasonableness, not certainty.
 Wilson J. made that clear in Debot, at p. 1168 S.C.R. She
said that a consideration of whether information is compelling,
from a credible source, and corroborated is not a separate test,
but that the “totality of the circumstances” must meet the
standard of reasonableness. She added that weaknesses in one
area may, to some extent, be compensated by strengths in
the other two.
 The trial judge in this case lost sight of the reasonableness
standard. Information from a large corporation may be reasonably believed, even if it is known that the corporation makes
mistakes on occasion. In this case, Cst. MacDonald testified that
in his experience with some 30 cases, Microsoft had never made
a mistake in the information it reported to NCMEC and that was
subsequently passed on to the police.
 I agree with the observation of the SCAJ, at para. 87, that
The trial judge’s sole focus was on “verification of accuracy”, in other words,
“corroboration”. While referring to Debot, the trial judge erred in failing to
consider all the circumstances, including whether the information was
compelling, credible, to what extent was it corroborated and, if so, whether
considering the totality of the evidence, it was sufficient to meet the standard
 I conclude that the trial judge erred in law by applying an
incorrect standard to the ITO.