Kelly Douglas and Co. Ltd. v. The Queen, 82 DTC 6036, [1981] CTC 457 (BCSC) -- summary under Subsection 231.3(3)

"[T]he only seizure that is authorized is of documents that may afford evidence of a violation." Consequently, "the authorization [of the judge] does not permit documents to be taken that have not been examined or searched for their evidentiary value in proving a violation". Because this standard was not met by the "wholesale seizure" of the taxpayer's documents, and because there had been material non-disclosure in the affidavits in support of the application, all the seized documents were ordered to be returned.