Sure.
The Alberta Court of Appeal, in a case called Lerke, a 1986 judgment, determined that the charter in fact did apply to citizen's arrest. The basis for that conclusion was really an historical analysis that was done on the power of citizen's arrest, that in fact the power of citizen's arrest pre-dates the police arrest power. There was a time when we didn't have a police force and we relied on citizens to effect arrest and this arrest power was derived directly from the sovereign. So this power that was granted by the sovereign was subject to the charter on that basis, that it came directly from the sovereign.
There's a tendency to think that the citizen's arrest power actually came after the police arrest power, and that's not the case. The Alberta Court of Appeal ruled early on that citizen's arrest was subject to the charter. Other courts, including Ontario, I think Nova Scotia, and British Columbia have held otherwise.
The Supreme Court has not ruled on this issue.