As you indicated, the U.K. legislation provides for preventive detention of up to 28 days. Australian criminal law is a state issue as opposed to a federal issue. It varies from state to state, but in many states in Australia, preventive detention can be for up to 14 days.
Our bill is not focused on detention. It's focused on arresting the person, bringing them before a judge, and then releasing them with or without conditions. It's not presupposed that a person will be detained for a long period of time, so that's a major difference.
With respect to the investigative hearing, the United States has the grand jury system. Canada had the grand jury system up until the mid-1960s. It permits a person to be brought before a judge in order to be examined under oath to provide testimony prior to a charge. That does not exist in Canadian law anymore, although it did under the grand jury when we had it.
The one exception where it does exist under Canadian law is under the Mutual Legal Assistance in Criminal Matters Act. That act provides for a judge to order a person to attend before him or her to testify under oath for the purposes of obtaining evidence to send to a foreign country pursuant to their judicial request to provide mutual legal assistance.
Those are the comparisons to other legislation, as well as some other past or current precedents that we have in Canada.