Status of religious freedom in Canada
Encyclopedia
Freedom of religion
Freedom of religion is a principle that supports the freedom of an individual or community, in public or private, to manifest religion or belief in teaching, practice, worship, and observance; the concept is generally recognized also to include the freedom to change religion or not to follow any...
in Canada
Canada
Canada is a North American country consisting of ten provinces and three territories. Located in the northern part of the continent, it extends from the Atlantic Ocean in the east to the Pacific Ocean in the west, and northward into the Arctic Ocean...
is a constitutionally protected right, allowing believers the freedom to assemble
Freedom of assembly
Freedom of assembly, sometimes used interchangeably with the freedom of association, is the individual right to come together and collectively express, promote, pursue and defend common interests...
and worship
Worship
Worship is an act of religious devotion usually directed towards a deity. The word is derived from the Old English worthscipe, meaning worthiness or worth-ship — to give, at its simplest, worth to something, for example, Christian worship.Evelyn Underhill defines worship thus: "The absolute...
without limitation or interference.
Constitutional rights
The "Fundamental FreedomsSection Two of the Canadian Charter of Rights and Freedoms
Section Two of the Canadian Charter of Rights and Freedoms is the section of the Constitution of Canada's Charter of Rights that lists what the Charter calls "fundamental freedoms" theoretically applying to everyone in Canada, regardless of whether they are a Canadian citizen, or an individual or...
" section of the Canadian Charter of Rights and Freedoms
Canadian Charter of Rights and Freedoms
The Canadian Charter of Rights and Freedoms is a bill of rights entrenched in the Constitution of Canada. It forms the first part of the Constitution Act, 1982...
states:
- 2. Everyone has the following fundamental freedoms:
- (a) freedom of conscience and religion;
- (b) freedom of thought, belief, opinion and expression, including freedom of the press and other media of communication;
- (c) freedom of peaceful assembly; and
- (d) freedom of association.
Canadians are therefore free to have their own beliefs and opinions, are free to practise religion or refrain, and are free to establish media organizations with or without religious content. Canadian religious institutions generally benefit from charitable organization
Charitable organization
A charitable organization is a type of non-profit organization . It differs from other types of NPOs in that it centers on philanthropic goals A charitable organization is a type of non-profit organization (NPO). It differs from other types of NPOs in that it centers on philanthropic goals A...
status, which allows supporters to benefit from tax credits or deductions for their financial contributions.
According to the Charter's preamble
Preamble to the Canadian Charter of Rights and Freedoms
The preamble to the Canadian Charter of Rights and Freedoms is the introductory sentence to the Constitution of Canada's Charter of Rights and Constitution Act, 1982...
, Canada is founded upon principles that recognize the supremacy of God
Constitutional references to God
Several national constitutions make reference to God, most often in the preamble. Such invocationes or nominationes dei are found notably in several European constitutional traditions and in the constitutions of Islamic countries.In constitutional...
. This portion of the preamble has not been accorded legal effect in Charter jurisprudence.
The constitutional recognition of God has been criticized as conflicting in principle with the fundamental freedom of conscience and religion guaranteed in section 2, as it would disadvantage those who hold nontheistic
Nontheism
Nontheism is a term that covers a range of both religious and nonreligious attitudes characterized by the absence of — or the rejection of — theism or any belief in a personal god or gods...
or polytheistic
Polytheism
Polytheism is the belief of multiple deities also usually assembled into a pantheon of gods and goddesses, along with their own mythologies and rituals....
beliefs, including atheism
Atheism
Atheism is, in a broad sense, the rejection of belief in the existence of deities. In a narrower sense, atheism is specifically the position that there are no deities...
and Buddhism
Buddhism
Buddhism is a religion and philosophy encompassing a variety of traditions, beliefs and practices, largely based on teachings attributed to Siddhartha Gautama, commonly known as the Buddha . The Buddha lived and taught in the northeastern Indian subcontinent some time between the 6th and 4th...
.
Human rights codes
While religious freedoms are protected from state interference by the Charter, the actions of private individuals are largely governed by the provincial human rights codes. These codes prohibit discrimination in the marketplace, accommodation, and employment on the grounds of a variety of personal characteristics, including religion.Case law
Supreme Court of Canada
The Supreme Court of Canada is the highest court of Canada and is the final court of appeals in the Canadian justice system. The court grants permission to between 40 and 75 litigants each year to appeal decisions rendered by provincial, territorial and federal appellate courts, and its decisions...
ruled in Chaput v. Romain, regarding Jehovah's Witnesses
Jehovah's Witnesses
Jehovah's Witnesses is a millenarian restorationist Christian denomination with nontrinitarian beliefs distinct from mainstream Christianity. The religion reports worldwide membership of over 7 million adherents involved in evangelism, convention attendance of over 12 million, and annual...
, that all religions have equal rights, based upon tradition and the rule of law
Rule of law
The rule of law, sometimes called supremacy of law, is a legal maxim that says that governmental decisions should be made by applying known principles or laws with minimal discretion in their application...
. At the time, no statutes formed the basis for this argument.
Religious speech
In a 1985 Supreme Court case involving the Lord's Day Act, R. v. Big M Drug Mart Ltd.R. v. Big M Drug Mart Ltd.
R. v. Big M Drug Mart Ltd., [1985] 1 S.C.R. 295, is a landmark decision by Supreme Court of Canada where the Court struck down the Lord's Day Act for violating section 2 of the Canadian Charter of Rights and Freedoms...
, Chief Justice Brian Dickson said that religious freedom in Canada includes freedom of religious speech, including "the right to entertain such religious beliefs as a person chooses, the right to declare religious beliefs openly and without fear of hindrance or reprisal, and the right to manifest religious belief by worship and practice or by teaching and dissemination."
Canada has laws prohibiting the promotion of hatred
Hate speech
Hate speech is, outside the law, any communication that disparages a person or a group on the basis of some characteristic such as race, color, ethnicity, gender, sexual orientation, nationality, religion, or other characteristic....
against sections of the public distinguished by colour, race, religion, ethnic origin, or sexual orientation. There are safeguards in the Bill which exempt people expressing opinions on religious subjects and opinions based on religious texts.
In 1996, the Supreme Court of Canada held that the anti-Semitic
Anti-Semitism
Antisemitism is suspicion of, hatred toward, or discrimination against Jews for reasons connected to their Jewish heritage. According to a 2005 U.S...
publications of a New Brunswick
New Brunswick
New Brunswick is one of Canada's three Maritime provinces and is the only province in the federation that is constitutionally bilingual . The provincial capital is Fredericton and Saint John is the most populous city. Greater Moncton is the largest Census Metropolitan Area...
schoolteacher, challenged under provincial Human Rights Act, were protected by his right to freedom of religion, but that professional sanctions were a reasonable limit on that right, in order to maintain "a school system that is free from bias, prejudice and intolerance."
In 1997, Hugh Owen, a Saskatchewan prison guard, published an advertisement in the Star-Phoenix that referenced Bible verses related to homosexuality (without quoting them) and drew a line through an image representing a gay couple. A complaint was lodged with the Saskatchewan Human Rights Board of Inquiry. The Board ruled against Owen and that decision was also upheld by a lower court. On 13 April 2006 the Saskatchewan Court of Appeal overturned the previous decisions, ruling that while Owen's advertisement was "offensive and jarring to many", it was not illegal. The court also ruled that statements which are designed to provoke "extreme emotions and strong feelings of detestation, calumny and vilification" may be deemed as hate speech.
In 2000, Rev. Ken Campbell
Ken Campbell (evangelist)
Kenneth Livingstone Campbell was a Canadian fundamentalist Baptist evangelist and political figure. He was the final leader of the Social Credit Party of Canada from 1990 to 1993....
successfully defended against an Ontario Human Rights Commission complaint filed after he placed an advertisement in the Globe and Mail newspaper where he protested a Supreme Court of Canada ruling calling for Alberta to amend the Human Rights Code regarding LGBT issues. The ad began with "Supreme Court has no business imposing 'bathhouse morality' on the churches and in the living rooms of the nation." Two years later he successfully defended against a complaint filed at the BC Human Rights Tribunal for the same advertisement, with the decision stating "The essence of Mr. Campbell's defence is that the publication... is an expression of his Charter-protected rights to express his religious beliefs; that is, a finding of discrimination would impair both his freedom of expression and his freedom of religion."
Another high profile case involves Chris Kempling
Chris Kempling
Christopher Stephen Myles Kempling is a Canadian educator and counsellor who was suspended by the British Columbia College of Teachers and disciplined by the Quesnel School District for expressing opinions critical of homosexuality. Kempling challenged the suspension in court, arguing that his...
, a school teacher, who was suspended without pay in 2002 for writing letters to a local newspaper objecting to the introduction of LGBT
LGBT
LGBT is an initialism that collectively refers to "lesbian, gay, bisexual, and transgender" people. In use since the 1990s, the term "LGBT" is an adaptation of the initialism "LGB", which itself started replacing the phrase "gay community" beginning in the mid-to-late 1980s, which many within the...
-related material into the public school system, arguing against same-sex marriage, and advocating conversion therapy for gay and lesbian persons. Kempling appealed the suspension to the courts. The British Columbia Court of Appeal
British Columbia Court of Appeal
The British Columbia Court of Appeal is the highest appellate court in the province of British Columbia, Canada. The BCCA hears appeals from the Supreme Court of British Columbia and a number of boards and tribunals. The BCCA also hears criminal appeals from the Provincial Court of British...
found that his right to freedom of expression
Section Two of the Canadian Charter of Rights and Freedoms
Section Two of the Canadian Charter of Rights and Freedoms is the section of the Constitution of Canada's Charter of Rights that lists what the Charter calls "fundamental freedoms" theoretically applying to everyone in Canada, regardless of whether they are a Canadian citizen, or an individual or...
had been breached, but that the disciplinary action was a reasonable limit
Section One of the Canadian Charter of Rights and Freedoms
Section One of the Canadian Charter of Rights and Freedoms is the section of the Charter that confirms that the rights listed in that document are guaranteed. The section is also known as the reasonable limits clause or limitations clause, as it legally allows the government to limit an...
on his rights, as it was done with the objective of maintaining a tolerant and non-discriminatory school system.
Sabbath and holiday observance
In R. v. Big M Drug Mart, the Supreme Court of Canada held that the stated purpose of the federal Lord's Day Act, compelling observance of the Christian Sabbath, was incompatible with the protections of freedom of religion in the Charter. In 1986, in R. v. Edwards Books and Art, the Supreme Court found that legislation prohibiting Sunday shopping with the secular purpose of creating a day of rest was also a violation of freedom of religion because of the unequal effect of the law on retailers who observed a different sabbath. However, this violation was upheld as a justifiable limit on freedom of religion.The Supreme Court of Canada has ruled that there is a duty to accommodate religious observance under human rights legislation. The 1990 case Central Alberta Dairy Pool v. Alberta
Central Alberta Dairy Pool v. Alberta (Human Rights Commission)
Alberta Dairy Pool v. Alberta , [1990] 2 S.C.R. 489, is a leading Human Rights decision of the Supreme Court of Canada. The Court expanded on the concept of accommodation up to undue hardship first established in Ontario Human Rights Commission and O'Malley v...
concerned an employee who was required by his religion to take Easter Monday
Easter Monday
Easter Monday is the day after Easter Sunday and is celebrated as a holiday in some largely Christian cultures, especially Roman Catholic and Eastern Orthodox cultures...
as a holy day. As this is not a statutory holiday, his employer required that he work that day or lose his job. The Supreme Court of Canada found that the employer should have accommodated the employee's religious practices.
Religious dress
In a 1985 court case involving an employee of the Canadian National RailwayCanadian National Railway
The Canadian National Railway Company is a Canadian Class I railway headquartered in Montreal, Quebec. CN's slogan is "North America's Railroad"....
, K.S. Bhinder, a Sikh
Sikh
A Sikh is a follower of Sikhism. It primarily originated in the 15th century in the Punjab region of South Asia. The term "Sikh" has its origin in Sanskrit term शिष्य , meaning "disciple, student" or शिक्ष , meaning "instruction"...
whose religion required that he wear a turban, lost his challenge of the CNR policy that required him to wear a hard hat.
In the 1990 case of Central Alberta Dairy Pool, the Supreme Court of Canada overturned the 1985 Bhinder decision, saying: "An employer that has not adopted a policy with respect to accommodation and cannot otherwise satisfy the trier of fact that individual accommodation would result in undue hardship will be required to justify his conduct with respect to the individual complainant. Even then the employer can invoke the BFOQ (bona fide occupational qualification) defence."
In the 1991 case of Peel Board of Education v. Ontario Human Rights Commission, an Ontario school board's "zero tolerance" for weapons in its schools had an adverse impact on Khalsa
Khalsa
+YouWebImagesVideosMapsNewsMailMoreTranslateFrom: ArabicTo: EnglishEnglishHindiEnglishAllow phonetic typingHindiEnglishArabicAssumptionGoogle Translate for Business:Translator ToolkitWebsite TranslatorGlobal Market Finder...
Sikh men who are required by their religion to carry a kirpan
Kirpan
The kirpan is a ceremonial sword or dagger carried by orthodox Sikhs. It is a religious commandment given by Guru Gobind Singh at the Baisakhi Amrit Sanchar in CE 1699, all baptised Sikhs must wear a kirpan at all times....
, a ceremonial dagger. A Khalsa Sikh teacher brought a complaint under the Ontario Human Rights Code and was successful. The school board challenged this to the Ontario Divisional Court on the basis that there was a threat to public safety. The Divisional Court ruled that the threat to public safety from Sikhs was minimal and the discriminatory impact of the ruling on this religious group was significant. In 2006, the Supreme Court of Canada ruled in Multani v. Commission scolaire Marguerite‑Bourgeoys that Sikh children can wear a kirpan to school based on freedom of religion.
In 1995, the Federal Court of Appeal upheld the exemption for Sikhs from wearing the "Mountie hat" as part of the RCMP dress requirements.
Marital practice
Prior to 1798, only ministers of the Church of EnglandChurch of England
The Church of England is the officially established Christian church in England and the Mother Church of the worldwide Anglican Communion. The church considers itself within the tradition of Western Christianity and dates its formal establishment principally to the mission to England by St...
had the authority to solemnize legal marriages in Upper Canada
Upper Canada
The Province of Upper Canada was a political division in British Canada established in 1791 by the British Empire to govern the central third of the lands in British North America and to accommodate Loyalist refugees from the United States of America after the American Revolution...
. This power was extended by degrees to religious officials of various other Christian denominations over the first half of the 19th century, until an 1857 act granted the power to solemnize marriages to the ministers of every religious denominiation. A similar process occurred in Lower Canada
Lower Canada
The Province of Lower Canada was a British colony on the lower Saint Lawrence River and the shores of the Gulf of Saint Lawrence...
, with the main difference being that it was the Roman Catholic Church
Roman Catholic Church
The Catholic Church, also known as the Roman Catholic Church, is the world's largest Christian church, with over a billion members. Led by the Pope, it defines its mission as spreading the gospel of Jesus Christ, administering the sacraments and exercising charity...
which initially held the sole authority.
Polygamous marriages
Polygamy
Polygamy is a marriage which includes more than two partners...
, promoted by some religious minority groups, are illegal in Canada. Authorities often do not strictly enforce the applicable laws, as has been the case in Bountiful, British Columbia
Bountiful, British Columbia
Bountiful is a settlement located in the Creston Valley of southeastern British Columbia, Canada, near Cranbrook and Creston. The closest community is Lister, British Columbia....
. On January 12, 2006, the Department of Justice (Canada)
Department of Justice (Canada)
The purpose of the Department of Justice is to ensure that the Canadian justice system is fair, accessible and efficient. The Department also represents the Canadian government in legal matters...
released a study, authored by three law professors at Queen's University
Queen's University
Queen's University, , is a public research university located in Kingston, Ontario, Canada. Founded on 16 October 1841, the university pre-dates the founding of Canada by 26 years. Queen's holds more more than of land throughout Ontario as well as Herstmonceux Castle in East Sussex, England...
, recommending that Canada repeal the laws that make polygamy a criminal offence. See related article, Polygamy and religion.
In the 2003 case Halpern et al. v. Attorney General of Canada et al., the Ontario Court of Appeal rejected the argument that a failure of the law to recognize same-sex marriages violated the religious rights of the church that performed the ceremonies, though the court found the definition of marriage to be unconstitutional on other grounds.
Refusal of service
In 2000, Scott Brockie, a TorontoToronto
Toronto is the provincial capital of Ontario and the largest city in Canada. It is located in Southern Ontario on the northwestern shore of Lake Ontario. A relatively modern city, Toronto's history dates back to the late-18th century, when its land was first purchased by the British monarchy from...
printer, was fined $5,000 by the Ontario Human Rights Commission
Ontario Human Rights Commission
The Ontario Human Rights Commission was established in the Canadian province of Ontario on March 29, 1961 to administer the Ontario Human Rights Code...
for refusing to print letterhead, envelopes, and business cards for the Canadian Lesbian and Gay Archives
Canadian Lesbian and Gay Archives
The Canadian Lesbian and Gay Archives is a non-profit organization in Toronto, Ontario, Canada, which collects material relating to the history of lesbian, gay, bisexual and transgender communities in Canada....
. Brockie unsuccessfully appealed to the Ontario appellate court to overturn the fine. The court ruled that the order requiring Brockie to print the materials was a justifiable violation of Brockie's religious rights, though it limited the scope of the Commission's ruling to only ordinary material such as letterhead and envelopes, saying the Commission "ought not to require Mr. Brockie to print material of a nature that could reasonably be considered to be in direct conflict with the core elements of his religious beliefs."
In 2002, the Rainbow Harmony Project, a choir that supports LGBT
LGBT
LGBT is an initialism that collectively refers to "lesbian, gay, bisexual, and transgender" people. In use since the 1990s, the term "LGBT" is an adaptation of the initialism "LGB", which itself started replacing the phrase "gay community" beginning in the mid-to-late 1980s, which many within the...
persons, filed a complaint against Camp Arnes of Manitoba
Manitoba
Manitoba is a Canadian prairie province with an area of . The province has over 110,000 lakes and has a largely continental climate because of its flat topography. Agriculture, mostly concentrated in the fertile southern and western parts of the province, is vital to the province's economy; other...
, after the camp denied them access. The complaint was settled, with both parties issuing a joint statement that the conflict had resulted from uncertainty regarding that nature of the camp's rental operations, and the acknowledgement that they were "part of its broader religious mission and outreach and not primarily a commercial activity."
Eight Canadian marriage commissioners have argued that they should be permitted to claim a "right of conscience" in refusing to perform the marriages of same-sex couples. At present, commissioners appointed by the government are required to affirm all legal marriages which are brought before them. In 2005, Saskatchewan
Saskatchewan
Saskatchewan is a prairie province in Canada, which has an area of . Saskatchewan is bordered on the west by Alberta, on the north by the Northwest Territories, on the east by Manitoba, and on the south by the U.S. states of Montana and North Dakota....
commissioner Orville Nichols was fired for refusing to marry same-sex couples. Ordained religious ministers are not required to marry same-sex couples. A poll conducted in October 2006 found that 57% of Canadians believe that a marriage commissioner should be able to refuse to officiate at a gay wedding so long as there are enough marriage commissioners available, and 72% felt that clergy should have the right to refuse to officiate if doing so would violate his or her religious beliefs.
Refusal of medical treatment
A set of Jehovah's Witness parents refused blood transfusions for their 1-year-old daughter after doctors decided the baby urgently needed them. The baby was made a ward of the state in order to administer blood transfusions. The Supreme Court of Canada ruled that this was a legitimate limitation on religious freedom.Other caselaw
In 2004, Robert Allen lost a case he brought against the Council for the Corporation of the County of RenfrewRenfrew County, Ontario
Renfrew is a county in the Canadian province of Ontario. In 2006, the population was 97,545 and county covered , giving a population density of . There are 17 official municipalities.-Government:...
, where Allen attempted to prevent the council from opening each meeting with a prayer. The court found in favour of the council.
In the 2004 case Syndicat Northcrest v. Amselem
Syndicat Northcrest v. Amselem
Syndicat Northcrest v. Amselem [2004] 2 S.C.R. 551 was a decision of the Supreme Court of Canada that attempted to define freedom of religion under the Quebec Charter of Human Rights and Freedoms and section 2 of the Canadian Charter of Rights and Freedoms...
, the Supreme Court of Canada
Supreme Court of Canada
The Supreme Court of Canada is the highest court of Canada and is the final court of appeals in the Canadian justice system. The court grants permission to between 40 and 75 litigants each year to appeal decisions rendered by provincial, territorial and federal appellate courts, and its decisions...
ruled in favour of Jews seeking to build a succah hut despite a condominium agreement that prohibited the action.
Education
Canada's approach to religious educationReligious education
In secular usage, religious education is the teaching of a particular religion and its varied aspects —its beliefs, doctrines, rituals, customs, rites, and personal roles...
often faces concerns addressing to how to best balance competing concerns, e.g., anti-discrimination laws and religious freedoms, and respect rights to religious education outlined in important Canadian legal documents. Catholic education
Catholic school
Catholic schools are maintained parochial schools or education ministries of the Catholic Church. the Church operates the world's largest non-governmental school system...
public funding is mandated by various sections of the Constitution Act, 1867
Constitution Act, 1867
The Constitution Act, 1867 , is a major part of Canada's Constitution. The Act created a federal dominion and defines much of the operation of the Government of Canada, including its federal structure, the House of Commons, the Senate, the justice system, and the taxation system...
and reaffirmed by Section Twenty-nine of the Canadian Charter of Rights and Freedoms
Section Twenty-nine of the Canadian Charter of Rights and Freedoms
Section Twenty-nine of the Canadian Charter of Rights and Freedoms is the section of Charter that most specifically addresses rights regarding denominational schools and separate schools...
. The United Nations Human Rights Commission declared in 1999 that Ontario
Ontario
Ontario is a province of Canada, located in east-central Canada. It is Canada's most populous province and second largest in total area. It is home to the nation's most populous city, Toronto, and the nation's capital, Ottawa....
was in violation of the international covenant on civil and political rights by only funding Catholic schools and not other faith-based schools. In 2007, Ontario voters were polled as being opposed to extending funding to other faith groups. Newfoundland
Newfoundland and Labrador
Newfoundland and Labrador is the easternmost province of Canada. Situated in the country's Atlantic region, it incorporates the island of Newfoundland and mainland Labrador with a combined area of . As of April 2011, the province's estimated population is 508,400...
withdrew Catholic funding in 1996, via legislation that required approval from the Canadian House of Commons. Quebec
Quebec
Quebec or is a province in east-central Canada. It is the only Canadian province with a predominantly French-speaking population and the only one whose sole official language is French at the provincial level....
abolished religious education funded by the state through the Education Act, 1998 which took effect on July 1 of that same year.
In 2001, the Supreme Court of Canada ruled in Trinity Western University v. British Columbia College of Teachers
Trinity Western University v. British Columbia College of Teachers
Trinity Western University v. British Columbia College of Teachers, [2001] 1 S.C.R. 772, 2001 SCC 31, is a leading Supreme Court of Canada decision on the freedom of religion and the court's ability to review a private school's policies.-Background:...
that the British Columbia College of Teachers was wrong to withhold accreditation of Trinity Western University
Trinity Western University
Trinity Western University is a private, Christian liberal arts university located in Langley, British Columbia, Canada.The school was founded in 1962 as Trinity Junior College, and now enrolls approximately 4000 students and sits on a campus....
's teacher education program on the basis that their moral code contained provisions banning certain LGBT activities.
In a highly publicized 2002 case, Justice Robert McKinnon granted an interlocutory injunction ordering that Marc Hall
Marc Hall
Marc Hall v. Durham Catholic School Board was a 2002 court case in which Marc Hall, a Canadian teenager, fought a successful legal battle against the Durham Catholic District School Board to bring a same-sex date to his high school prom. The case made Canadian and international headlines.-Court...
be allowed to bring a same-sex date to prom at his Oshawa, Ontario
Oshawa, Ontario
Oshawa is a city in Ontario, Canada, on the Lake Ontario shoreline. It lies in Southern Ontario approximately 60 kilometres east of downtown Toronto. It is commonly viewed as the eastern anchor of both the Greater Toronto Area and the Golden Horseshoe. It is now commonly referred to as the most...
Catholic high school. The matter did not, however, proceed to trial, meaning no binding judgement on the merits of the case was issued.
In 2006, the Province of British Columbia moved to make changes that would require religious schools to teach LGBT-friendly educational material (see related article Peter and Murray Corren
Peter and Murray Corren
Peter Corren and Murray Corren — Corren is a combination of their former names — are LGBT-rights activists from Vancouver, British Columbia whose complaint before British Columbia's Human Rights Tribunal led to an agreement whereby the provincial Ministry of Education would consult them on how...
); however, the British Columbia government indicated that changes to the public education system were not intended to prevent religious schools from teaching their ethical codes of behaviour. Also in 2006, in Quebec, Christian evangelical schools are now being required to teach both evolution and sex education, a requirement that does not exist in some other provinces.