The common law power of seizure incident to arrest does not require exact temporal coincidence between arrest and seizure; a seizure during a record of interview on the same morning as the arrest is sufficiently close to be incidental to the arrest. A safety search resulting in temporary custody of items for non-investigative purposes does not constitute a 'seizure'. Where tendency evidence in a multi-complainant online grooming case reveals a remarkably similar pattern of conduct across complainants, it is likely to have significant probative value substantially outweighing prejudicial effect.
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