Il convient de rappeler que les témoignages relatifs à une pratique courante ou habituelle, même pris isolément, peuvent servir de base pour conclure qu'une action a été accomplie d'une certaine manière

R. v. Ashmore, 2011 BCCA 18

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[60]           While it is true that Mr. Dumonceaux could not independently recall his interaction with Mr. Ashmore, he was able to testify with considerable specificity as to the substance of their conversation on the basis of the standard form he completed at the time and his customary practice.  Mr. Ashmore, on the other hand, only had a vague recollection of their conversation.

[61]           It was open to the trial judge to prefer Mr. Dumonceaux’s evidence for the reasons he gave.  In this regard, it is to be remembered that testimony regarding standard or habitual practice, even standing alone, can serve as the basis for finding that something was done in a certain way.  As Mr. Justice Seaton stated in Belknap v. Meakes (1989), 1989 CanLII 5268 (BC CA), 64 D.L.R. (4th) 452 at 465 (B.C.C.A.):

            If a person can say of something he regularly does in his professional life that he invariably does it in a certain way, that surely is evidence and possibly convincing evidence, that he did it in that way on the day in question.

See also:  R. v. Thompson (2001), 2001 CanLII 24186 (ON CA), 151 C.C.C. (3d) 339 at paras. 7-9 (Ont. C.A.); R. v. Cunningham, 2006 ABCA 345, 401 A.R. 35 at paras. 4, 5.