Gosselin before the Supreme Court
File Number: 29298
IN THE SUPREME COURT OF CANADA
(APPEAL FROM THE COURT OF APPEAL FOR THE PROVINCE OF QUEBEC)
Between:
Roger Gosselin
Guylaine Filion
Daniel Trépanier
Claudette Gosselin
Guy Boulianne
Johanne Labbé
Alain Chénard
Rachel Guay
Gilles Maltais
Guylaine Potvin
Jean-Marie Martineau
Mance Bourassa
Marc Joyal
Marie-Irma Cadet
René Giguère
Lucille Giordano
Appellants
(Appellants)
- and -
The Attorney General of Quebec
Minister of Education
Respondents
(Respondents)
- and -
Commissioner of Official Languages
Intervener
FACTUM OF THE INTERVENER,
COMMISSIONER OF OFFICIAL LANGUAGES
(Rule 42)
| François Boileau Counsel for the Intervener, Commissioner of Official Languages Office of the Commissioner of Official Languages |
| ORIGINAL TO: THE REGISTRAR COPIES TO: | |
| Brent D. Tyler Counsel for the Appellant 83 Saint Paul Street West Montreal, Quebec H2Y 1Z1 Tel.: (514) 845-4880 Fax: (514) 842-8055 Email: brenttyler@videotron.ca | Marie-France Major Ottawa agent for the Appellant 300 – 50 O’Connor Street Ottawa, Ontario K1P 6L2 Tel.: (613) 232-7171 Fax: (613) 231-3191 Email: mmajor@langmichener.ca |
AND: | |
| Benoit Belleau Counsel for the Respondent Attorney General of Quebec Bernard, Roy & Associés 8.01-1 Notre-Dame Street East Montreal, Quebec H2Y 1B6 Tel.: (514) 393-2336 Fax: (514) 873-7074 Email: bbelleau@justice.gouv.qc.ca | Sylvie Roussel Ottawa agent for the Respondent Attorney General of Quebec Noël & Associés 111 Champlain Street Hull, Quebec J8X 3R1 Tel.: (819) 771-7393 Fax: (819) 771- 5397 |
TABLE OF CONTENTS
PART III - Statement of Argument
- Basis of minority rights and their interaction with equality rights
- Principle of the protection of minorities in Canada
- Purpose of s.23 of the Charter
- Background to the adoption of s.23 of the Charter
- The minority language education right at s. 23 versus access, by the majority, to minority language education
II - Non-discrimination within the meaning of ss. 10 and 12
of the Quebec Charter
- Differential Treatment
- Whether differential treatment is discriminatory
PART I - STATEMENT OF FACTS
1. The Intervener, the Commissioner of Official Languages for Canada (hereinafter "the Commissioner"), is the federal ombudsman for official languages. Her mandate, specified in s. 56 of the Official Languages Act, R.S.C. 1985 (4th Supp.), c. 31 (hereinafter "the OLA"), indicates that it is the duty of the Commissioner "to take all actions and measures ... with a view to ensuring recognition of the status of each of the official languages ... including ... the advancement of English and French in Canadian society." Section 2(b) of the OLA also indicates that the purpose of the OLA is to support the development of English and French linguistic minority communities. It is with this in mind that the Commissioner is intervening in the present case.
2. The Intervener, the Commissioner, is relying on the statement of facts contained in the appellants' memorandum and on the summary of proceedings at paras. 8 to 13 of the judgment of the Quebec Court of Appeal.
3. However, the Commissioner wishes to emphasize that none of the parties to this proceeding can rely on s. 23 of the Canadian Charter of Rights and Freedoms since the appellant parents have not received primary education in English in Canada.
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PART II - POINTS IN ISSUE
A) Are ss. 72 and 73 of the Charter of the French Language inconsistent with ss. 10 and 12 of the Charter of Human Rights and Freedoms?
4. The Commissioner maintains that, in light of Canadian case law, it is not discriminatory for the Charter of the French Language (hereinafter the "CFL") to give "Anglophone" parents, contrary to "Francophone" and "allophone" parents, the freedom to choose the language in which their children will be educated in Quebec public schools.
B) Alternatively, if the Court were to find that discrimination exists, what obligations would the Quebec legislature have, given the obligations set out in s. 23 of the Canadian Charter of Rights and Freedoms?
5. Whatever steps the Quebec legislature may be required to take in order to comply with the Charter of Human Rights and Freedoms (hereinafter "the Quebec Charter"), the Commissioner maintains that the concept of equality must not jeopardize the rights set out in s. 23 of the Canadian Charter of Rights and Freedoms (hereinafter "the Charter").
PART III - STATEMENT OF ARGUMENT
6. As an amicus curiae, the Commissioner maintains that the appellants' position, if approved, would have the effect of distorting s. 23 of the Charter by granting parents the choice of sending their children to minority language schools, including those not entitled to do so pursuant to the Charter.
7. The appellants argue that English language education in Quebec is a public service to which children would be entitled were it not for the exclusion based on their civil status, in view of ss. 72 and 73 of the CFL.
The proper definition of the 'public' for the service of English language instruction in Quebec is the class of all school-age children in the province. All school-age children would be eligible were it not for the restrictions in ss. 72 and 73 CFL. To hold otherwise, i.e., to define the 'public' only as the class of school-age children that are 'ordinarily' eligible for English language instruction under the provisions of the CFL, as the trial judge did, is circuitous." [Emphasis added].
Para. 39, appellants' memorandum
See also para. 44, appellants' memorandum
8. The appellants make a direct connection between the rights set out in s. 23 of the Charter and access to education in Quebec English language schools. The Commissioner maintains that it is fundamentally important to distinguish the right mentioned in s. 23 from access to education under a provincial statute.
9. Section 23 of the Charter is one of a body of constitutional rules that seeks to protect and promote the development of linguistic minorities in Canada. The CFL, for its part, is intended to protect and promote French in Quebec which is a minority language in Canada but a majority language in Quebec. Accordingly, it is necessary, for a proper understanding of the interactions between these two legal documents, to examine the basis of minority rights and to briefly describe the principal legal means for ensuring that those rights are observed in Canada.
Mahe v. Alberta, [1990] 1 S.C.R. 342
(i) - Basis of minority rights and their interaction with equality rights
10. Equality has to be considered in a substantive sense, not a purely formal one. This means that, in order to achieve equality, it is permissible for certain persons to be granted a different treatment when justified by the different situation or needs of such persons.
Law v. Canada (Minister of Employment and Immigration), [1999] 1 S.C.R. 497, at para. 24.
11. Accordingly, the granting of rights to members of minorities can be explained by the principle of substantive equality. It is generally more difficult for the members of a minority culture or language group to develop and pass on their language or culture to their children than it is for members of the majority.
12. A minority group might be a victim of substantive inequality even though, in purely formal terms, all individuals have been treated in the same way, which is to say that members of the minority have the same rights as members of the majority.
See in general C. Taylor, Multiculturalisme : Difference et démocratie, Paris, Aubier, 1994, at pp. 42 to 99; W. Kymlicka, La citoyenneté multiculturelle, Montréal, Boréal, 2001, at pp. 226 to 230.
13. It is with a view to correcting this substantive inequality that many countries have introduced a legislative scheme benefiting their cultural, linguistic or religious minorities. This movement in favour of minority rights has also led to the adoption of international treaties to the same effect.
International Covenant on Civil and Political Rights (1976), 999 U.N.T.S. 107, art. 27; Declaration on the Rights of Persons Belonging to National or Ethnic, Religious and Linguistic Minorities, U.N. Resol. 47/135 (December 18, 1992, 32 I.L.M. 911); Framework Convention for the Protection of National Minorities (Council of Europe, February 1, 1995, 34 I.L.M. 351).
14. The Supreme Court of Canada recognized the connection between the right to equality, in its substantive (or real) sense, and the rights of minorities in Arsenault-Cameron, which dealt with s. 23 of the Charter. Major and Bastarache JJ. stated the following:
Section 23 is premised on the fact that substantive equality requires that official language minorities be treated differently, if necessary, according to their particular circumstances and needs, in order to provide them with a standard of education equivalent to that of the official language minority.
Arsenault-Cameron v. Prince Edward Island, [2000] 1 S.C.R. 3, at para. 31.
15. This connection between substantive equality and the rights of minorities implies that the granting of special rights to a minority is not discrimination per se.
16. In Law, the Supreme Court held that the fact that the purpose of a legislative provision is to improve the situation of a minority or a disadvantaged group is a factor that tends to demonstrate that the provision in question is not substantively discriminatory.
Law, supra note at para.10 at paras. 72 and 73.
17. Finally, the Commissioner agrees with the analysis of the Court of Appeal when it refers to Adler, in which the Supreme Court of Canada noted that the granting of certain rights to Roman Catholics did not give rise to a duty to grant the same rights to other religious communities.
Gosselin et al. v. Quebec (Procureur general), [2002] J.Q. no. 1126 at para. 26.
Adler v. Ontario, [1996] 3 S.C.R. 609, at 641.
(ii) - Principle of the protection of minorities in Canada
18. Canadian society is ethnically, linguistically and religiously diverse. This diversity stems from the existence of minorities. Some of these minorities are part and parcel of the historical process that gave rise to Canada and are, so to speak, integral parts of Canada. It should surprise no one that Canada's constitutional structure grants an important place to the rights of those minorities, so much so that the Supreme Court has held that the protection of minorities is one of the fundamental principles of the Constitution.
Reference re Secession of Quebec, [1998] 2 S.C.R. 217, at paras. 79 to 82.
19. In linguistic terms, Canada distinguishes itself by the existence of an Anglophone majority and a Francophone minority located primarily in Quebec but existing, in varying degrees, in each province and territory. In 1867, when the present federal structure was created, the province of Quebec was created to allow Francophones, concentrated in that province, to govern themselves in a number of areas that had significance for their language and culture.
20. Accordingly, when the National Assembly adopts statutes to protect the French language and culture, those statutes constitute one of the most important means of protection available to the largest Francophone minority in Canada. In Ford, the Supreme Court recognized the legitimacy of such legislation when it held that preserving the "visage linguistique français" of Quebec was an objective sufficiently important to justify the predominance of French on bilingual signs in that province. This legitimacy was also recognized by the Court in Reference re Secession of Quebec:
The principle of federalism facilitates the pursuit of collective goals by cultural and linguistic minorities which form the majority within a particular province. This is the case in Quebec, where the majority of the population is French-speaking, and which possesses a distinct culture. This is not merely the result of chance. The social and demographic reality of Quebec explains the existence of the province of Quebec as a political unit and indeed, was one of the essential reasons for establishing a federal structure for the Canadian union in 1867 ... The federal structure adopted at Confederation enabled French-speaking Canadians to form a numerical majority in the province of Quebec, and so exercise the considerable provincial powers conferred by the Constitution Act, 1867 in such a way as to promote their language and culture.
Reference re Secession of Quebec, supra note at para. 18, at para. 59.
Ford v. Quebec (Attorney General), [1988] 2 S.C.R. 712, at pages 777-779.
21. However, federalism by itself does not provide complete protection for linguistic minorities. There is a significant Anglophone minority in Quebec and a significant Francophone minority in the other provinces. This is why legal means have been taken to protect the linguistic minorities in each province.
22. Certain language rights have been granted only to members of the official language linguistic minority in certain provinces. Section 93 of the Constitution Act, 1867, in so far as its concrete effect is to guarantee rights with a linguistic component, falls within this category. The same is true of s. 23 of the Charter, the provision at issue here, although that section obviously applies in all provinces and territories.
(iii) - Purpose of s. 23 of the Charter
23. Section 23 of the Charter has to be read together with s. 59 of the Constitution Act, 1982, which provides that s. 23(1)(a) does not come into force in respect of Quebec until the Quebec government has given its consent. That consent has never been given.
24. Shortly after the Charter was adopted, the Supreme Court held, in Hunter, that the interpretation of Charter rights must be undertaken in accordance with their purpose. Specifically, a purposive interpretation is the proper method of giving meaning to the language rights guaranteed by the Charter, including s. 23.
Hunter v. Southam Inc., [1984] 2 S.C.R. 145, at pages 155-157.
Mahe, supra note at para. 9 at pages 361-362; Reference re Public Schools Act (Man.), s. 79(3), (4) and (7), [1993] 1 S.C.R. 839, at pages 850-852; R. v. Beaulac, [1999] 1 S.C.R. 768, at para. 25; Arsenault-Cameron, supra note at para. 14, at para. 27.
(iv) - Background to the adoption of s. 23 of the Charter
25. From the outset, the Commissioner wishes to highlight the context in which this case arises. We are dealing with a provincial linguistic minority in Quebec (Anglophones) and a national linguistic minority elsewhere in Canada (Francophones) whose interests must be reconciled. The combination of these two minorities does not exist in the other provinces, where the provincial linguistic majority is also the national majority.
26. In Mahe, the Supreme Court described the general purpose of s. 23 as follows:
The general purpose of s. 23 is clear: it is to preserve and promote the two official languages of Canada, and their respective cultures, by ensuring that each language flourishes, as far as possible, in provinces where it is not spoken by the majority of the population. The section aims at achieving this goal by granting minority language educational rights to minority language parents throughout Canada.
Mahe, supra note at para. 9, at p. 362.
27. The Court also echoed these comments in Arsenault-Cameron.
Arsenault-Cameron, supra note at para. 14, at para. 26.
28. In short, it is clear that, in 1982, the framers wanted to avoid entrenching free choice of the language of education. That choice was conferred only on the members of the official language minority in each province.
29. Ultimately, the Commissioner maintains that s. 23 of the Charter is essentially intended to guarantee constitutional protection for the right to education in the language of the minority provided by schools controlled by the minority.
Mahe, supra note at para. 9.
Arsenault-Cameron, supra note at para. 14.
(v) - The minority language education right at s. 23 versus access, by the majority, to minority language education
30. The Commissioner submits that it is important not to do as the appellants and the respondents have done, in that they have confused the right to minority language education for the minority and access by the majority to education in English in Quebec and in French in the other Canadian provinces and territories.
Appellants' memorandum, at para. 31.
Respondents' memorandum, at para. 112.
31. It has been established that a fundamental difference exists between the constitutional right to receive education in the language of the minority, for recipients who meet the requirements of s. 23(1) and (2) of the Charter, and access for the majority to a school and education in the language of their choice.
Anglophone parents in Ontario do not have a constitutional right to have their children educated in French as a matter of choice. Their children cannot be admitted to a French language school unless an admissions committee, controlled by members of the minority group, grants them access : Michel Bastarache, André Braën, Emmanuel Didier and Pierre Foucher, Language Rights in Canada, Michel Bastarache ed. (Montréal, Yvon Blais Inc., 1989).
Abbey et al. v. Essex County Board of Education, [1999] 42 O.R. (3d) 490 (C.A.), at 488.
32. The Quebec Court of Appeal agreed with this proposition and has stated the following :
[TRANSLATION]
Additionally, as already noted, the Ontario Court of Appeal has indicated that s. 23 was not intended to give members of the Ontario majority the right to have their children educated in French in the language of the minority in publicly-funded schools.
Solski v. Quebec (Procureure générale), [2002] J.Q. no. 1127 at para. 71.
33. This is consistent with the approach taken by the Supreme Court of Canada with regards to the need to avoid dissociating schools from their community and with regards to the importance of maintaining and promoting education in the language and culture of the minority.
Arsenault-Cameron, supra note at para. 14, at para. 45.
34. What is actually at issue is whether members of the linguistic majority in Quebec can, by relying on their equality rights, claim access for their children the right to an English-language education.
35. To the extent that such a claim involves access to schools controlled and administered by the Anglophone minority of Quebec, the Commissioner believes that this question should be answered in the negative as such access would be contrary to the spirit and purpose of s. 23 of the Charter.
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II - Non-discrimination within the meaning of ss. 10 and 12 of the Quebec Charter
36. The Commissioner of Official Languages supports the respondents' arguments and the conclusions of the Quebec Court of Appeal in this matter. However, she wishes to further clarify certain aspects, in the event that this Court analyzes arguments dealing strictly with the question of discrimination within the meaning of s. 10 of the Quebec Charter. The Commissioner adopts the arguments made by the respondents regarding the relevance of s. 12 of the Quebec Charter.
37. To determine whether a legislative provision is contrary to the equality right contained in s. 15 of the Charter, the courts have applied a tripartite analysis described by the Supreme Court in Law, supra. The Quebec Court of Appeal also applies this analytical grid to alleged infringements of s. 10 of the Quebec Charter. In Law, the Supreme Court described these three points as follows:
Accordingly, a court that is called upon to determine a discrimination claim under s. 15(1) should make the following three broad inquiries:
(A) Does the impugned law (a) draw a formal distinction between the claimant and others on the basis of one or more personal characteristics, or (b) fail to take into account the claimant's already disadvantaged position within Canadian society resulting in substantively differential treatment between the claimant and others on the basis of one or more personal characteristics?
(B) Is the claimant subject to differential treatment based on one or more enumerated and analogous grounds?
and
(C) Does the differential treatment discriminate, by imposing a burden upon or withholding a benefit from the claimant in a manner which reflects the stereotypical application of presumed group or personal characteristics, or which otherwise has the effect of perpetuating or promoting the view that the individual is less capable or worthy of recognition or value as a human being or as a member of Canadian society, equally deserving of concern, respect and consideration?
Law, supra note at para. 10, at para. 88.
See also, for application of case law on s. 15 of the Charter to s. 10 of the Quebec Charter, Johnson v. Lester B. Pearson School Board, [2000] R.J.Q. 1961 (C.A.); Québec (Procureur général) v. Lambert, [2002] R.J.Q. 599 (C.A.).
38. In the alternative, the Commissioner submits that, contrary to the reasons of the Court of Appeal, an affirmative answer should be given to the first question in the test suggested in Law, namely the questions dealing with differential treatment (A). However, the Commissioner contends that the question of whether the differential treatment is discriminatory (C) should be answered in the negative.
(i) - Differential treatment
39. In its reasons, the Court of Appeal indicated that the first test, based on differential treatment, had not been met. It seems clear from reading ss. 72 and 73 of the CFL that there is differential treatment of children who do not fall within the exceptions mentioned in s. 73 of the CFL. Parents who are members of the majority are deprived of a benefit or advantage that the law grants to Anglophone parents, namely the ability to choose the language of education of their children.
(ii) - Whether differential treatment is discriminatory
40. However, the Commissioner believes that the question of whether the differential treatment is discriminatory must be answered in the negative. In Law, the Supreme Court indicated that when a court is required to determine whether a legislative provision is actually discriminatory, it must examine four contextual factors that are suggestive of whether the provision is contrary to the purpose of the right to equality, that is guaranteeing the dignity of all members of society. Those factors are:
- the victim's association with a group that has historically been the object of stereotypes, been in a disadvantaged situation or has been deprived of political power;
- the correspondence, or lack thereof, between the grounds on which the differential treatment is based and the actual need, capacity or circumstances of the victim;
- the fact that the impugned legislative provision is intended to improve the position of a disadvantaged group; and
- the nature and scope of the right or interest affected by the impugned provision.
41. The first factor is association with a disadvantaged group. The language policy in question was adopted by the National Assembly, a democratic institution in which Quebec Francophones constitute an overwhelming majority. In this respect, Quebec Francophones are not deprived of political power. The first factor therefore is not present.
42. The second factor is the correspondence between the differential treatment established by the legislation and the actual requirements or circumstances of the group in question. It is natural to assume that the members of a linguistic group have a much greater interest in receiving education in their language than do those who are not members of that group. Although the test used, namely the language of the primary education of one of the parents, is not perfect, it is a valid indicator of the linguistic community to which the child belongs. The Commissioner therefore believes that there is in fact a correspondence between the test in s. 73 of the CFL and the actual circumstances of those to whom it applies.
43. The third factor is the purpose of the impugned measure. In the case at bar, it is clear that the CFL seeks to improve the situation of Francophones in Quebec, considered a minority within Canada and North America, by taking measures necessary for the survival and the development of the French language. Although Quebec Francophones are a majority in Quebec and are not deprived of political power in areas that fall within the jurisdiction of the National Assembly, they are also a minority within Canada. Accordingly, as the Supreme Court recognized in Ford and in the Reference re the Secession of Quebec, it is legitimate for the National Assembly to adopt legislation to accomplish this purpose and make certain distinctions by means of legislation.
Ford, supra note at para.20, at p. 777.
Reference re Secession, supra note at para. 18, at para. 59.
44. It should also be noted that the differential treatment of Anglophones and Francophones that is made in s. 73 of the CFL seeks to protect the Anglophone minority in Quebec by granting it special rights. This minority is to some extent deprived of political power in matters within provincial jurisdiction, such as education, even though such concerns have been echoed in certain aspects of s. 23 of the Charter. In short, the differential treatment at issue makes it possible to reconcile the interests of two minorities, Anglophones within Quebec and Quebec Francophones within Canada.
45. The fourth factor is the nature of the interest affected. This involves the right of parents to choose the language in which their children will be educated. Despite the importance some have sought to attribute to this right, it must be noted that neither in Canada nor abroad is this regarded as a fundamental right. The language of education is ordinarily determined by the country's language policies, not by the parents' choices. In Canada, s. 23 of the Charter does not, in general, recognize such freedom of choice. Other countries with more than one official language, such as Belgium and Switzerland, determine the language of education on a territorial basis, leaving parents no freedom of choice.
Jacques Leclerc, Langue et société, 2d ed., Montréal, Mondia, 1992, at pages 448-449 (Belgium) and pages 459-460 (Switzerland).
46. To conclude, the Commissioner believes that an analysis of the contextual factors mentioned by the Supreme Court in Law indicates that the fact that the CFL gives Anglophones, but not Francophones, the freedom to choose the language of education of their children is not substantively discriminatory against Francophones. Although they are a minority within Canada, Francophones are not, in Quebec and within areas of provincial jurisdiction, a minority deprived of political power, which is the archetype of groups protected by the equality guarantee. Minority rights are justified especially when a group is deprived of the political power by which it could defend its own interests. Intervention by the judiciary applying a charter of rights is then justified.
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PART IV - SUBMISSION ON COSTS
47. The Intervener, the Commissioner of Official Languages, makes no submission regarding costs.
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PART V - ORDER SOUGHT
48. The Intervener, the Commissioner for Official Languages, takes no position regarding the outcome of the present appeal.
RESPECTFULLY SUBMITTED ON FEBRUARY 10, 2004.
François Boileau
Counsel for the Intervener,
Commissioner of Official Languages
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PART VI - CASE LAW AND AUTHORITIES
Case Law
Abbey et al. v. Essex County Board of Education, [1999] 42 O.R. (3d) 490 (C.A.)
Adler v. Ontario, [1996] 3 S.C.R. 609
Arsenault-Cameron v. Prince Edward Island, [2000] 1 S.C.R. 3
Ford v. Quebec (Attorney General), [1988] 2 S.C.R. 712
Gosselin et al. v. Quebec (Procureur général), [2002] J.Q. no.1126 (C.A.)
Hunter v. Southam Inc., [1984] 2 S.C.R 145
Johnson v. Lester B. Pearson School Board, [2000] R.J.Q. 1961 (C.A.)
Law v. Alberta (Minister of Employment and Immigration), [1999] 1 S.C.R. 497
Mahe v. Alberta, [1990] 1 S.C.R. 342
Québec (Procureur général) v. Lambert, [2002] R.J.Q. 599 (C.A.)
R. v. Beaulac, [1999] 1 S.C.R. 768
Reference Re Public Schools Act (Man), s. 79(3), (4) and (7), [1993] 1 S.C.R. 839
Reference re Secession of Quebec, [1998] 2 S.C.R. 217
Solski v. Quebec (Procureure générale), [2002] J.Q. no.1127 (C.A.)
Authorities
Leclerc, J., Langue et société, 2d ed., Montréal, Mondia, 1992
Kymlicka, W., La citoyenneté multiculturelle, Montréal, Boréal, 2001
Taylor, C., Multiculturalisme : Différence et Démocratie, Paris, Aubier, 1994
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PART VII - STATUTES/REGULATIONS
Canadian Charter of Rights and Freedoms, Part I of the Constitution Act, 1982, being Schedule B to the Canada Act 1982 (U.K.) 1982, c.11.
Charter of the French Language, R.S.Q. c. C-11
Charter of Human Rights and Freedoms, R.S.Q. c.C-12
Constitution Act, 1867 (U.K.), 30 & 31 Vict., c.3, reprinted in R.S.C. 1985, App. II, No. 5
Constitution Act,1982 being Schedule B to the Canada Act 1982 (U.K.), 1982, c.11
Declaration on the Rights of Persons Belonging to National or Ethnic, Religious and Linguistic Minorities, U.N. Resol. 47/135 (December 18, 1992, 32 I.LM. 911)
Framework Convention for the Protection of National Minorities (Council of Europe, February 1, 1995, 34 I.L.M. 351)
International Covenant on Civil and Political Rights (1976), 999 U.N.T.S 107
Official Languages Act, R.S.C. 1985 (4th Supp.), c.31
