While it is undoubtedly not the most ground breaking decision, the Ontario Court of Appeal's recent ruling in R v Calvert, 2011 ONCA 579 is nonetheless noteworthy. The issue upon which the appellant sought leave to appeal was the trial judge's decision, on his own initiative, to use Google maps to consider the issue of ASAP in an impaired case.
In dismissing the leave application the Court of Appeal offered the following:
...it was reasonable for the trial judge to take judicial notice of the distance between the arrest scene and the police station. In this regard, we note that the appellant accepts that generally speaking maps may be relied on by the courts when taking judicial notice because maps are a readily accessible source of indisputable accuracy [para 8].