In R. v. D.M. (Ont CA, 2023) the Court of Appeal considered that the foundation for a photograph may be made by anyone familiar with the scene from personal experience:
[31] It is well-established that a person present for an event depicted in photographs may be in a position to authenticate photographs and that, as a result, it is not always necessary to call the photographer as a witness to authenticate photos: R. v. B.S., 2019 ONCA 72; David M. Paciocco, Palma Paciocco & Lee Stuesser, The Law of Evidence, 8th ed. (Toronto: Irwin Law, 2020), at p. 559.
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