With thanks to lawyers Félix Bernard, Yann Canneva, Catherine Cayer, Simon Chénard, Tina Hobday and Guillaume François Larouche and law student Meena Mrakade.
On May 24, 2022, the Quebec government adopted the Act respecting French, the official and common language of Québec (the “Act”). The Act received Royal Assent on June 1st, 2022 and can now be found in Chapter 14 of the 2022 Annual Volume of the Statutes of Quebec (SQ 2022, c. 14).
The Act introduces a broad reform of the Charter of the French language (the “Charter”) and makes amendments to other statutes as well.
Through this reform, the Government of Quebec has not only affirmed that French is the only official language of Quebec, but also that it is the only common language of the Quebec nation.1 To this end, this reform:
- Amends the Charter;
- Recognizes new fundamental language rights;
- Establishes measures to strengthen and enforce the provisions of the Charter;
- Introduces changes relating to the use of French in the workplace, in business, and in education; and
- Creates the Ministry of the French Language and provides for the appointment of a French Language Commissioner.
The legal system in Quebec is thus significantly transformed across many spheres of activity. Below, our team presents an overview of the main changes resulting from this legislative reform.
The amendments made to the Charter’s preamble, as well as the general provisions, outline, from the outset, the objectives underlying the reform. In particular, the introductory provisions of the Charter now state that:
- The National Assembly recognizes that French is the common language of the Quebec nation and that everyone must be made aware of the importance of the French language and Quebec culture;2
- It is incumbent on the National Assembly, not only to confirm the status of French as the official and common language, but also to enshrine the paramountcy of that status in Quebec’s legal order;3
- The French language is the only official language in Quebec.4
A separate chapter has been added to the Charter and concerns the characterization of French as the common language of the Quebec nation.5
This chapter of the Charter explicitly provides that, from now on, French is:
- The language of integration for immigrants;
- The language of intercultural communication to enable all to participate in public life in Quebec; and
- The language that allows people to adhere and contribute to the distinct culture of Quebec’s population.6
The Charter also provides that Quebecers who do not speak French are encouraged to learn the language.7 Finally, the Charter specifies that the government must take measures to:
- Promote the learning of French;
- Promote its use, by all, as a common language; and
- Ensure its vitality and continuity.8
In the chapter on fundamental language rights, the Charter is amended to recognize the right of all people to access justice and legislation in French.9
Furthermore, the Charter is amended to specify that, where there is a discrepancy between the French and English versions of a statute, and where the ordinary rules of interpretation do not resolve the discrepancy, the French text will prevail.10
In addition, substantial new provisions are added to the Charter with respect to the use of French and the use of other languages in various texts, documents, and acts relating to legislation and the justice system. For example:
- Certain regulations and other acts of a similar nature to which section 133 of the Constitution Act, 1867 does not apply, such as municipal by-laws, must, from now on, be drafted, adopted, and published exclusively in French;11
- All companies (legal persons) will only be permitted to file legal proceedings in English when accompanied by a certified French translation by an accredited translator, at the filing party’s expense.12 This new requirement will have significant consequences for legal persons or companies instituting proceedings in Quebec or having to defend themselves before the Quebec courts. It will come into force on September 1st, 2022;
- A judgment or decision that is final in nature or of public interest and that is rendered in English by a court of law or a person or body exercising adjudicative functions will have to be accompanied, without delay, by a French version.13 This new requirement will come into force on June 1st, 2024;
- In the context of a grievance arbitration, a disagreement or a dispute concerning the negotiation, renewal, review, interpretation or application of a collective agreement, any arbitral award rendered in English shall be accompanied, without delay, by a French version, with the cost of translation to be borne by the parties.14 This amendment will come into force on June 1st, 2024.
According to another central amendment to the administration of justice, it will no longer be permitted to require that a person who will be appointed as a judge or to an adjudicative function by the government of Quebec to have knowledge or a specific level of knowledge of a language other than French, subject to exceptions.15
Several changes will also be brought to the Charter with respect to the use of French in dealings with, and within, Quebec’s public service, including government departments and agencies. For example, Quebec’s public sector employees must exclusively use French when communicating internally in the performance of their duties, both orally and in writing.17 This new requirement will come into force on June 1st, 2023.
With respect to the relations between private companies and the Administration, we highlight, among others, the following changes, which will come into force on June 1st, 2023:
- In principle, public contracts, including those related to subcontracting, must be drawn up exclusively in French.18 This requirement also applies to written documents relating to these contracts (whether they are written documents sent to the Administration in order to enter into a contract with it, those relating to a contract to which the Administration is a party or those transmitted under such a contract from one party to another);19
- However, the Charter will allow that certain agreements (and related written documents) be accompanied by a version in a language other than French.20 that in certain listed situations, public contracts (and related written documents) be accompanied by a version in a language other than French,21 that certain public contracts be drawn up both in French and in another language22 or be drafted in another language (in which case the Administration will be required to make a French version of these contracts or documents available to the public sector employees who are required to examine them in the course of their duties);23
- With some exceptions, written documents sent to an agency of the Administration by a legal person or company in order to obtain a permit or similar authorization, a subsidy or other form of financial aid, as well as the written documents related to them must be drafted exclusively in French;24
- Services rendered to the Administration by a legal person or company must be rendered in French. Where the services obtained as such are intended for the public, the provisions that would apply if the Administration itself were rendering these services will apply to the legal person or enterprise.25
The Charter now further regulates the professional bodies and their members on matters concerning the use of French, notably by requiring that members maintain a knowledge of French that is adequate for the practice of their profession.26
Any member who contravenes this obligation commits an act derogatory to the dignity of his or her profession and may therefore be subject to disciplinary sanctions by his or her professional body.27
In addition, professional bodies may, from now on, only issue permits to persons who do not have a knowledge of the French language which is deemed appropriate to the practice of his or her profession in certain situations.28 Furthermore, barring exceptions, a professional may no longer refuse to provide a service solely because he or she is required to do so in French.29
Moreover, from now on, the Charter provides that professional bodies can only use French in their communications, written or oral, with their members and candidates to the practice of the profession.30 Barring exceptions,31 this requirement also applies to specific communications with a member or a candidate to the practice of the profession.32 This amendment could restrict the possibility for professional bodies to send bilingual communications or notices in English to their members or the public.
As it relates to the language of labour relations, it is important to note that the Charter now defines more specifically certain terms relating to labour law to which it refers, such as “employee”, “worker”, and “employer”.33
Also, the Charter now expressly states that employers must respect the workers’ right to exercise their activities in French, which entails a series of obligations, particularly with regards to posting employment or promotion offers, drafting employment contracts, using French in written communications with staff and drafting documents relating to training or working conditions.34
Furthermore, the Charter has been amended as it relates to prohibited practices in the context of language requirements. It now specifically prohibits employers from imposing any sanction or reprisal on a member of their staff for a series of reasons relating to the right of an employee to exercise his or her activities in French.35
Henceforth, the Charter also prohibits the employer from requiring that a person have knowledge or a particular level of knowledge of any language other than French in order to remain in a position or gain access to it, unless the performance of the duties of the position requires such knowledge. In that case, the employer must have already taken all reasonable measures to avoid imposing such a requirement. When he or she imposes such a requirement to attain a position, the employer must specify the reasons behind the requirement when posting the offer.36
In this regard, it is worth noting that an employer requiring the knowledge or a given level of knowledge of any language other than French is now considered a prohibited practice, unless he or she demonstrates that the performance of the duties of the position requires such knowledge, and that the employer has already taken all reasonable measures to avoid imposing such a requirement.37 Demonstrating that such reasonable measures have been taken is quite complex and involves the following elements:38
- The employer must have assessed the actual language needs associated with the duties to be performed;
- The employer must have ascertained that the language skills already required of other staff members were insufficient for the performance of these duties;
- The employer must have restricted the number of positions involving duties for which the performance requires knowledge or a given level of knowledge of any language other than the official language to a minimum.
The legislator has taken the time to specify, during the study of the Act, that an employer will not have to carry out an unreasonable restructuring of his or her company in order to establish these elements.39 The scope of this clarification and of the applicable test is likely to raise its own share of questions.
The Charter has also been amended to provide for direct recourse to the CNESST for an employee who believes that he or she has been the victim of reprisals or who believes that he or she has been unlawfully required to have a given level of knowledge of any language other than French.40
Finally, the Charter now grants a right for all employees to a workplace free from discrimination or harassment based on the language of work, as well as a requirement for the employer to take all reasonable measures to prevent such conduct and to put an end to it when he or she becomes aware of it.41
To learn more about the consequences of the amendments made by the Act on labour law, see our other post.
In communications between companies and their customers, the Act amends the Charter to provide an explicit requirement42 for companies offering goods and services to consumers to respect their right to be informed and served in French.43 Companies offering goods and services to non-consumers must also inform and serve its clientele in French. This new measure is in line with the government’s stated desire to prioritize French greetings in commercial establishments, particularly following the Minister’s statements regarding the use of “bonjour-hi” as a greeting.
The Act also reinforces certain obligations in the context of commercial advertising. In addition to catalogues, brochures, leaflets, business directories, invoices, and receipts, the Charter now requires that order forms and other documents of a similar nature be written in French when they are available to the public.44 A version of the French document may be provided in another language only if the French version is available on terms that are at least as favourable.45
It seems that the government did not see fit to take advantage of the opportunity presented by this reform to specify that the Charter covers websites used for commercial purposes. The scope of the Charter in this respect has been clarified by the courts in well-established case law and by the interpretation given to it by the OQLF.46
ii) French as the language of contracts
The reform also provides a new framework intended to prioritize the use of French in contracts of adhesion.
The Charter will be amended to provide that, in principle, contracts of adhesion must be drafted in French. If they are drawn up in another language, they will only be binding on the parties if they explicitly consent to it, after the French version has been delivered to the adhering party.47
A series of exceptions to this rule are included. In addition to employment contracts, certain contracts of adhesion identified in the Charter will be exempted. These are mainly contracts concluded in the financial sector or which have extraneous elements. In these cases, the contracts may only be drafted in a language other than French if both parties explicitly consent to it. This exception will also apply to contracts containing standard clauses which are not contracts of adhesion.
The Consumer Protection Act will also be amended to provide that parties will not be able to validly consent to a consumer contract being drawn up in a language other than French without a French version of the contract having first been given to the consumer.48
This new framework concerning contracts of adhesion and consumer contracts will come into force on June 1st, 2023.
Furthermore, the French language requirement is, from now on, extended to contracts and the following acts, unless the parties expressly agree to draft these documents in another language49:
- Contracts for the sale or exchange of part or all of a mainly residential property of fewer than five (5) dwellings and certain mainly residential condominiums;
- A promise to sell or exchange such a property;
- The preliminary contract as it relates to the sale of a residential property, built or to be built, by a builder or developer;50
- The informational memorandum as it relates to the sale of a fraction of a divided co-property or of the sale of an undivided co-property share in a residential property.51
iii) Commercial advertising and public signs
Commercial signage is also covered by the Charter’s reform. Significant amendments were made to the Regulation respecting the language of commerce and business52 (the “Regulation”) in 2016, introducing a requirement to ensure a sufficient presence of the French language in outdoor signage when a trademark is displayed in another language.53 When it comes to public signage and commercial advertising, the Regulation currently provides that a trademark may only be written in a language other than French if it is “recognized” within the meaning of the Trademarks Act.54
The Charter provides, by means of new provisions, a framework for public signs visible from the exterior of the premises as well as the use of trademarks in public signage and commercial advertising. A trademark written exclusively in a language other than French may henceforth only be used under two (2) conditions:
- The trademark has been registered within the meaning of the Trademarks Act; and
- No corresponding French version can be found on the register under that Act.
As for public signs visible from the exterior of the premises, French must be markedly predominant in two (2) situations:
- When these signs include the name of a company containing an expression taken from another language; or
- When they include a trademark written in a language other than French.
It is important to note that this concept of marked predominance is the subject of a separate regulation, which specifies its scope.55
These two requirements added to the Charter will come into force on June 1st, 2025.
To learn more about the impact of the amendments brought by the Act to the language of commerce and business, see our other posts:
The Charter’s provisions will remain essentially unchanged with respect to the language of instruction at the preschool, elementary and secondary levels. However, several new measures will soon come into force for higher education, particularly college education.
One of the most notable changes concerns the proportion of students in English-language CEGEPs, which will not exceed 17.5% of the total number of students in the college system.56 A uniform French examination will be compulsory for students in English-language CEGEPs, except for those who have received their primary and secondary education in English.57
These amendments will come into force in the 2023-2024 school year.58
The Charter already established a francization process for companies. With the Act’s reform, this approach to francization is widely modified. The following are the main changes that have been, or will be made:
|Current Charter||Amended Charter||Coming into force|
|Number of employees over a period of six (6) months requiring registration with the OQLF||50||2559||June 1st, 2025|
|Time limit for submitting a post-registration analysis to the OQLF||6 months||3 months60||June 1st, 2022|
|Time limit for submitting a francization program to the OQLF, where applicable||6 months||3 months61||June 1st, 2022|
|Frequency of reports to be submitted to the OQLF regarding the implementation of the francization program, where applicable||Less than 100 employees: 24 months|
100 or more employees: 12 months
|12 months62||June 1st, 2022|
Furthermore, it is important to note that the Charter now provides that francization committees must meet at least every six (6) months.63
It also provides that an enterprise registered with the OQLF must henceforth be represented by a member of senior management as well as by a representative of the francization committee.64
It will be of particular importance for enterprises to comply with the requirements concerning francization. Indeed, from now on, the OQLF will publish and update a list of enterprises for which it has refused to issue an attestation or suspended or cancelled an attestation or a certificate.65
The Charter now also includes new provisions pertaining to francization in “certain other enterprises”. Annually, the OQLF will determine, for the sectors of activity it determines, the enterprises which are subject to the Act respecting the legal publicity of enterprises employing at least five (5) individuals to whom it will offer to set up French language learning services provided by Francisation Québec66. These added provisions will come into force on June 1st, 2023.
In addition, the Administration may no longer enter into a contract with an enterprise of at least 25 employees that is required to comply with the francization in the following cases:67
- The enterprise does not have an attestation of registration;
- The enterprise has not provided an analysis of its linguistic situation within the deadlines;
- The enterprise does not have an attestation of application to the francization process or a francization certificate;
- The enterprise appears on the list kept by the OQLF of enterprises for which it has refused to issue an attestation or for which an attestation certificate has been suspended or cancelled.
Similarly, the Administration may no longer enter into a contract with or provide a grant to an enterprise to which will apply the new francization process for “certain other enterprises” when this enterprise has refused the OQLF’s offer to set up French language learning service provided by Francisation Québec, unless it has agreed to do so thereafter, or if this enterprise has not complied with the terms and conditions agreed upon with Francisation Québec.68 This provision will come into force on June 1st, 2023, as will the francization process for “certain other enterprises”.
Although less impactful for individuals’ and businesses’ rights, but nonetheless symbolically significant, the Charter institutes the Ministry of the French Language.69
The Minister’s primary mission is to “promote, assert the value of and protect the French language and its status,” both for the present and the future, and to advise the government.70 The Minister will table an annual report to the National Assembly on the implementation of the Charter.71
The Act significantly strengthens the role of the OQLF. In addition to the inspection and investigative powers currently provided for in the Charter, the OQLF will be given the mandate to receive complaints regarding any contravention of the Charter and to direct the complainant to the appropriate forum (either the CNESST, a workers’ association, the Commission des droits de la personne et des droits de la jeunesse, or the French Language Commissioner).72 When the complaint falls under the jurisdiction of the OQLF, it may take measures to ensure that perpetrator ceases the breaching behaviour73 and that the situation is not repeated.74
Other notable changes to the role of the OQLF include the following:
- Any individual who wishes to report a breach of the Charter must contact the OQLF. The individual may do so regardless of any restriction that could apply to their communications under Quebec law, any provision of a contract or any duty of loyalty or confidentiality (including any duty of loyalty or confidentiality to the individual’s employer or client). However, the lifting of professional secrecy does not apply to professional secrecy between a lawyer or a notary and their client75;
- The individual who discloses a breach in good faith to the OQLF is protected by law and the OQLF is required to ensure that their anonymity is preserved;76
- In the event of a breach of the Charter, the OQLF has the power to issue orders with which the person responsible for the breach must comply;77
- The OQLF may also apply to the Superior Court for an injunction against a private company to enforce the Charter.78
The Charter’s reform intensifies the consequences which can be imposed in the event of a breach of the Charter. Notably:
- The Minister of the French Language, after consultation with the OQLF, may revoke a permit or similar authorization held by a company that repeatedly contravenes the Charter79;
- The provisions of a decision, act or contract may be declared void if they constitute a breach to the provisions of the Charter (however, proof of damage is required in certain situations)80;
- For the purposes of applying article 1435 CCQ, the adhering party in a contract of adhesion is presumed to be unaware of an external provision drafted in a language other than French, unless the contract has been drafted in the other language at his or her request81;
- For the purposes of applying article 1436 CCQ, a provision drafted in a language other than French is deemed incomprehensible, unless the contract has been drafted in the other language at the request of the weaker party82.
The framework for penal sanctions in the Charter is also amended.
Anyone who contravenes to, notably, an order issued by the OQLF requiring the perpetrator of a breach of the Charter to become complaint or to cease the breach is guilty of an offense and could be liable to a fine83. The applicable fine can range from $700 to $7,000 for an individual or $3,000 to $30,000 for a corporation.
Anyone who divulges information that he or she knows to be false or misleading in the context of a denunciation to the OQLF or anyone who retaliates against an individual who has made a denunciation in good faith to the OQLF is also guilty of an offense and could be liable to a fine.84 The applicable fine can range from $2,000 to $20,000 for an individual and $10,000 to $250,000 in other cases.
Minimum and maximum fines are doubled for a second offense and tripled for any subsequent offense.85
Minimum and maximum fines for individuals are doubled for directors and officers.86
An offense which occurs over more than one day is considered a separate offense for each day on which it continues.87
With the avowed intention of shielding the reform of the Charter from potential court challenges, the government invoked the notwithstanding clause under both the Canadian88 and Quebec Charters.89 The use of the notwithstanding clause is generalized: all amendments brought about by the Act are covered by the notwithstanding clause and it is invoked with respect to all the rights and freedoms from which it is permissible to derogate.90
The Act also proposes to amend the Constitution Act, 1867 to provide that Quebecers form a nation and that French is both the common language of the Quebec nation and its only official language.91 This measure has a powerful symbolic impact and enshrines the vision of the proposed amendments to the Charter. It is expected that this measure will provoke a debate concerning the power of the Quebec legislature to amend the Canadian constitution without Parliament’s consent.
This article provides an overview of the main amendments to the Charter that have been, or will be, brought to the Charter. Companies and organizations are advised to take a closer look at the new requirements that will apply to them and explore the possible exceptions or exemptions from which they may benefit. We will be tracking the interpretation and treatment of this new version of the Charter with great interest.
1 Preamble of the Charter (amended by art. 1 of the Act).
2 Preamble and art. 1(2) of the Charter (amended, respectively, by art. 1 and 2 of the Act).
3 Preamble of the Charter (amended by art. 1 of the Act).
4 Art. 1(1) of the Charter (amended by art. 1 of the Act).
5 Chapter VIII.2 (art. 88.9 et seq.) of the Charter (added by art. 62 of the Act).
6 Art. 88.9 of the Charter (added by art. 62 of the Act).
7 Art. 88.10 of the Charter (added by art. 62 of the Act).
8 Art. 88.13 of the Charter (added by art. 62 of the Act).
9 Art. 6.2 of the Charter (added by art. 4 of the Act).
10 Art. 7.1 of the Charter (added by art. 5 of the Act).
11 Art. 8 of the Charter (amended by art. 5 of the Act).
12 Art. 9 of the Charter (amended by art. 5 of the Act).
13 Arts. 10 and 11 of the Charter (amended by art. 5 of the Act).
14 Art. 44 of the Charter (amended by art. 32 of the Act).
15 Arts. 12 and 13 of the Charter (amended by art. 5 of the Act).
16 The government and its agencies are defined in the Act as the “civil administration”. The term Administration is used in this text for clarity. Note that the various agencies of the civil administration are defined at Schedule 1 of the Charter (art. 98 of the Charter).
17 Art. 18.1 of the Charter (added by art. 10 of the Act).
18 Art. 21(1) of the Charter (amended by art. 13 of the Act).
19 Art. 21.3 of the Charter (added by art. 14 of the Act).
20 Arts. 21.1, 21.2, and 21.3 of the Charter (added by art. 14 of the Act).
21 Art. 21.4 of the Charter (added by art. 14 of the Act).
22 Art. 21(2) of the Charter (amended by art. 13 of the Act) and art. 21.3 of the Charter (added by art. 14 of the Act).
23 Art. 21.5 to 21.7 of the Charter (added by art. 14 of the Act).
24 Art. 21.9 of the Charter (added by art. 14 of the Act).
25 Art. 21.11 of the Charter (added by art. 14 of the Act).
26 Art. 35.1 of the Charter (added by art. 23 of the Act).
27 Art. 51.9.3 of the Professional Code (added by art. 142 of the Act).
28 Art. 37 of the Charter (amended by art. 24 of the Act).
29 Art. 35.1 of the Charter (added by art. 23 of the Act).
30 Art. 32 of the Charter (amended by art. 21 of the Act).
31 Art. 40.2 of the Charter (added by art. 27 of the Act).
32 Art. 32 of the Charter (amended by art. 21 of the Act).
33 Art. 40.3 to the Charter (added by art. 28 of the Act).
34 Art. 41 of the Charter (amended by art. 29 of the Act).
35 Art. 45 of the Charter (amended by art. 33 of the Act).
36 Art. 46 of the Charter (amended by art. 35 of the Act).
37 Art. 45 of the Charter (amended by art. 33 of the Act).
38 Art. 46.1 of the Charter (added by art. 36 of the Act) a contrario.
39 Art. 46.1 of the Charter (added by art. 36 of the Act)
40 Art. 47 of the Charter (amended by art. 37 of the Act).
41 Art. 45.1 of the Charter (added by art. 34 of the Act).
42 Art. 50.2 of the Charter (added by art. 41 of the Act).
43 Art. 5 of the Charter.
44 Art. 52 of the Charter (amended by art. 43 of the Charter).
45 Ibid.; art. 57 of the Charter (amended by art. 46 of the Act).
46 See for example: Quebec (Attorney General) v. Aroyan, 2006 QCCQ 6922.
47 Art. 55 of the Charter (amended by art. 44 of the Act).
48 Art. 26 of the Consumer Protection Act (amended by art. 151 of the Act).
49 Art. 55.1 of the Charter (added by art. 45.1 of the Act).
50 As provided for in Art. 1785 C.C.Q.
51 As provided for in Art. 1787 C.C.Q.
52 Chapter C-11, r. 9.
53 Art. 25.1 of the Regulation.
54 Art. 25 of the Regulation.
55 Regulation defining the scope of the expression “markedly predominant” for the purposes of the Charter of the French language, chapter C-11, r.11.
56 Art. 88.0.4 of the Charter (added by art. 58 of the Act).
57 Art. 88.0.12 of the Charter (added by art. 58 of the Act).
58 Art. 201 of the Act.
59 Art. 139 of the Charter (amended by art. 81 of the Act).
61 Art. 140 of the Charter (amended by art. 83 of the Act).
62 Art. 143 of the Charter (amended by art. 85 of the Act).
63 Art. 138.3 of the Charter (added by art. 80 of the Act).
64 Art. 139.1 of the Charter (added by art. 82 of the Act).
65 Art. 152 of the Charter (added by art. 93 of the Act).
66 Art. 149 of the Charter (added by art. 89 of the Act).
67 Art. 152.1 of the Charter (added by art. 93 of the Act).
69 See Art. 94 of the Act, which inserts Title II.1 – Minister of the French Language and Ministère de la Langue française.
70 Art. 155 of the Charter (added by art. 94 of the Act).
71 Art. 156.4 of the Charter (added by art. 94 of the Act).
72 Art. 165.17 of the Charter (added by art. 94 of the Act).
73 The OQLF may order the party to comply with the requirements of the Charter, or to stop contravening it.
74 Art. 165.17 of the Charter (added by art. 107 of the Act).
75 Art. 165.22 of the Charter (added by art. 107 of the Act).
76 Arts. 165.23 to 165.26 of the Charter (added by art. 107 of the Act).
77 Arts. 177 to 182 of the Charter (added by art. 113 of the Act).
78 Arts. 183 and 184 of the Charter (added by art. 113 of the Act).
79 Art. 204.27 of the Charter (added by art. 114 of the Act).
80 Art. 204.17 of the Charter (added by art. 114 of the Act).
81 Art. 204.24 of the Charter (added by art. 114 of the Act).
82 Art. 204.25 of the Charter (added by art. 114 of the Act).
83 Art. 205 of the Charter (amended by art. 114 of the Act).
84 Art. 205.1 of the Charter (amended by art. 114 of the Act).
85 Art. 206 of the Charter (amended by art. 114 of the Act).
86 Art. 207 of the Charter (amended by art. 114 of the Act).
87 Art. 208 of the Charter (amended by art. 115 of the Act).
88 Constitution Act, 1982, Schedule B to the Canada Act 1982 (UK), 1982, c. 11.
89 Charter of Human Rights and Freedoms, CQLR, c. C-12.
90 Arts. 213.1 and 214 of the Charter (added by art. 118 of the Act); arts. 199 and 200 of the Act.
91 Arts. 90Q.1 and 90Q.2 of the Constitution Act, 1867 (added by art. 159 of the Act).