Is a search for illegal drugs incidental to an arrest for obstruction of justice?

Applying the law as articulated in R v. Caslake, to the facts of the present case, it is clear that the police did not search the appellant’s car for purposes of finding evidence related to the reason for his arrest. The police were searching for illegal drugs. That objective is entirely unrelated to an arrest for obstruction of justice. On their own admission, the police were acting for reasons unrelated to the arrest. If follows that the search in question was not truly incidental to the arrest and, therefore, the appellant’s right to be free of unreasonable searches, under s. 8 of the Charter, was violated.