Legislative Omissions subject to the CharterVriend v. Alberta,  1 SCR 493
Facts: A private religious college dismissed Vriend because of his sexual orientation. Vriend was unable to file a complaint under Alberta Human Rights legislation, which intentionally left out sexual orientation as a category protected from discrimination.
Issue: does the Charter apply to omissions in legislation?
- applicability of the Charter, s 32, is not only limited to positive government acts
- it can apply to omissions
- this is a violation of s 15
- it is not justified under s 1
- court reads into the legislation protection from discrimination on basis of sexual orientation
Ratio: omissions in legislation can amount to a Charter violation.