In the case of Hill v. Hamilton‑Wentworth Regional Police Services Board (2007) the Canada Supreme Court ruled that:

1. The police are not immune from liability under the law of negligence and the tort of negligent investigation exists in Canada.
2. Police officers owe a duty of care to suspects. Their conduct during an investigation should be measured against the standard of how a reasonable officer in like circumstances would have acted. Police officers may be accountable for harm resulting to a suspect if they fail to meet this standard.

This was not an interrogation case but focused on the way photo lineups were conducted.† It points out the importance of properly obtaining confessions in all cases.