Ontario Human Rights Code

On June 15, 2012, the Ontario Heritage Trust and the Ontario Human Rights Commission unveiled a provincial plaque at Hart House at the University of Toronto in Toronto, Ontario, to commemorate the Ontario Human Rights Code.

The plaque reads as follows:


    The Ontario Human Rights Code came into effect on June 15, 1962 and established equal rights and freedom from discrimination as primary elements of provincial law. The first legislation of its kind in Canada, the Code was designed to affirm and uphold the “inherent dignity and the equal and inalienable rights of all members of the human family” by providing a legal mechanism to combat discrimination. The Code was inspired by principles of individual liberty and minority rights established in Canadian constitutional traditions, and by international human and civil rights movements that emerged after the Second World War. It consolidated and expanded existing anti-discrimination statutes to reflect the changing attitudes of Ontarians toward race, religion and equality rights. Since 1962, the Code has broadened in scope, establishing Ontario as a national and international leader in human rights promotion and protection. It continues to make Ontario a more just, equitable and inclusive society.

Historical background

    “... human rights legislation in this province is based on the recognition of the fact that a person is not free if, by reason only of his particular race, colour, or creed, he is denied employment or access to services and accommodations which are normally available to the public.”1

Ontario’s Human Rights Code came into effect on June 15, 1962. By consolidating and expanding existing anti-discrimination legislation, the Code built on past achievements and signalled a significant step forward for human rights in Ontario. The seeds of the Code were sown in the decades – and even the centuries – prior to its enactment.

Efforts by the inhabitants of what is now Ontario to define and assert rights and freedoms are at least as old as the province itself. From the early years of Upper Canada until well into the 20th century, inhabitants of present-day Ontario often viewed rights and freedoms as entitlements that derived from British political and legal traditions. Those campaigning for reform and self-government in the 1820s and 1830s, for example, appealed to perceived rights under British law as they attempted to wrest power away from unelected elites. More than a century later, a leading civil rights advocate pointed to British legislation – the Magna Carta, the Petition of Right of 1628, the Bill of Rights of 1688 and the Act of Settlement of 1700 – as the “four beacons” that guided Canadian liberty.2

In addition to these traditions, however, there developed in Canada unique approaches to rights that grew out of exchanges and relationships between First Nations, French and British communities. These approaches often emphasized group rights and were expressed in acts of parliament, such as the Quebec Act (1774), the Constitutional Act (1791), Upper Canada’s Act to Limit Slavery (1793) and the British North America Act (1867) – all of which contained protections for minority groups. Although often quite limited, these protections helped to create a foundation upon which a pluralistic, multicultural society could be established.

There remained, however, major failings and shortcomings in Canadian and Ontario law that allowed, and even fostered, oppression, discrimination and intolerance. The unique mix of nations and cultural communities that gave rise to some progressive legislation also resulted in instances of appalling systemic racism, sectarianism and injustice. In the late 19th and early 20th centuries, as an increasingly diverse range of immigrants arrived and as new notions of equality, tolerance and citizenship were being formulated, the need for rights reform became increasingly urgent. Subsequently, in the middle decades of the 20th century, significant changes occurred in Ontario law and society that ushered in what has since been referred to as a “rights revolution.”

The origin of much of this change can be traced to the impact of the First World War. The war’s heavy toll – combined with burgeoning nationalist feelings, not only in Canada, but among the many relatively new nation states of Europe – created tensions, amplified rhetoric and stressed divisions based on race and ethnicity. In Canada, anti-foreigner sentiment – directed mostly toward Japanese, Germans and Eastern Europeans – led to the Wartime Elections Act of 1917, which, although it gave many women the right to vote, disenfranchised many foreign-born Canadians. Changes to the Immigration Act restricted immigration and prevented certain races, as well as those deemed “undesirable” because of their political affiliations, sexual orientation or perceived mental fitness, from entering the country. Prior to the First World War, immigration officials placed importance on the contributions that prospective immigrants could make to the Canadian economy. After the war the emphasis was on ethnicity and culture, and these became determining factors for immigration.

Anti-foreigner sentiment was exacerbated by the Great Depression, when many Canadians feared that immigrants would take much needed jobs away from those born in Canada. As a result of these factors, Canada would not receive substantial numbers of immigrants until the 1950s and foreign-born Canadians experienced widespread harassment and discrimination.3 Another consequence of the First World War, however, was that many of the fundamental beliefs upon which British and Canadian society were predicated began to be questioned and criticized. The notion that there existed a righteous, monolithic British/Canadian culture, guided by benevolent leaders and destined for greatness, was undermined by the experience of war and economic depression, and was slowly re-evaluated and dissected in the decades that ensued. This opened up space for new ideas about Canadian culture and society that would largely take shape after the Second World War.

Into the first decades of the 20th century, the fact that everyone did not enjoy equal rights was a reality of daily life in Canada. Restrictive covenant laws in various parts of the country – including many parts of Ontario – prevented individuals and families from residing in certain neighbourhoods on the basis of their ethnic, racial and religious background. At the same time, racial segregation was practiced in Southern Ontario schools. Minorities were refused service at many businesses and restaurants, and were regularly denied business licences. Under the Indian Act, Aboriginal peoples were denied political and civil rights. From the 1870s until the 1990s, for example, the Canadian government supported the residential school system that forcibly separated Aboriginal children from their families and communities with the aim of assimilating them into Euro-Canadian culture.4 Racial minorities across the country suffered from diverse forms of discrimination. Tragically, the Second World War witnessed the widespread internment of Japanese-Canadians – as well as Italian and German immigrants – by the Canadian state. In addition to these blatant acts of discrimination, immigration policies in Canada were explicitly racist until the 1960s.5

An early effort to combat discrimination through legislation occurred in 1933, when a private member’s bill was introduced into the Ontario Legislature that attempted to end the display of discriminatory signs in businesses and restaurants. Signs announcing “no Blacks,” “Whites only,” “Gentiles only” and “no Jews or dogs” were not uncommon in the province – and elsewhere in Canada – during this period. Sadly, the bill was defeated on the grounds that it was “impractical” and would interfere with individual rights.6 The struggle for human rights in the province of Ontario continued and gained strength in the years and decades following this defeat. It was a struggle that inspired revolutionary changes in law, ideology, and practice provincially, nationally and internationally.7

In the first half of the 20th century, non-discrimination was widely perceived as an ideal requiring volunteerism and goodwill, not as a right requiring laws.8 In fact, laws preventing acts of discrimination were viewed as threats to individual freedoms.9 As a result, Canada was one of the least hospitable places for Jewish refugees fleeing Europe during the Second World War.10 The racist atrocities of the Second World War, however, had a profound effect on Canadian society, and the post-war period witnessed an important shift in social attitudes and values.11 By war’s end Jewish refugee relief was a pressing Canadian issue. Private and public outrage was generated by the fact that members of ethnic and religious minorities who had served overseas returned to find that many of the rights and freedoms for which they fought were not being extended to them at home in Canada. It was also during this time that domestic anti-Semitism and racial and religious prejudice were recognized as larger social problems that were not only unjust but also threatened social stability and progress. There developed a growing perception that in order to effectively combat discrimination, minority groups had to work together and provide mutual support. A leading proponent of this idea was Kalmen Kaplansky. A printer by profession, Kaplansky was the national director of the Jewish Labour Committee between 1946 and 1957. His adoption of an active, multifaceted approach to countering discrimination became hugely influential. Kaplansky stated, “Education, legislation, and social action are part and parcel of a comprehensive approach to developing a practical campaign aimed at minimizing the effects of racial and ethnic discrimination and developing an affirmative program.”12

In the years following the Second World War the idea of “human rights” was gaining currency. This notion was bolstered and given definition when the Universal Declaration of Human Rights, which was adopted by the United Nations General Assembly in 1948, created new international standards of human rights.13 As a new culture of rights emerged, existing racial hierarchies were challenged. Canada’s legal apparatus – which often protected perpetrators and neglected the victims of discrimination – increasingly became a subject of concern. Gradually, the government assumed increasing responsibility for countering discrimination.14

Anti-discrimination legislation in the 1940s and 1950s put Ontario’s human rights program on track. The 1944 Racial Discrimination Act banned discriminatory signs and publications. The following year, the future Lieutenant Governor of Ontario Keiller Mackay, who was then a Supreme Court of Ontario judge, struck down restrictive covenants in the landmark case Re Drummond Wren. Keiller Mackay – together with a group of legal scholars and civil advocates that included Bora Laskin, Mark MacGuigan and Harry Arthurs – would go on to form the Canadian Civil Liberties Association in 1964, which has provided leadership on rights issues ever since.

In 1950, there was an amendment to Ontario’s Labour Relations Act that prevented collective agreements from discriminating on the basis of race or creed; a bill prohibiting the enforcement of restrictive covenants followed soon after. That same year, the federal government established a House and Senate committee, chaired by Arthur Roebuck, which held public hearings on the issue of entrenching rights in the Canadian Constitution.15

In the early 1950s, after tireless campaigning by groups such as the National Unity Association of Chatham, Dresden and North Buxton (led by seasoned Black Dresden activist Hugh Burnett), the Progressive Conservative government of Ontario, under the leadership of Leslie Frost, passed what became collectively referred to as “fair practices” legislation, including the country’s first Fair Employment Practices Act and a Female Employees Fair Remuneration Act, both passed in 1951, and the Fair Accommodation Practices Act passed in 1954. Instead of relying on litigation through the court system – as discrimination cases had previously – the legislation emphasized conciliation and the settlement of complaints through negotiation between the relevant parties. Ontario’s foray into human rights legislation had a “snowball effect.” Within five years, similar laws were enacted in five other Canadian provinces.16 According to political scientist R. Brian Howe, in addition to practical effects, “policy served as a symbolic force in elevating the principle of human rights, drawing attention to the discrepancies between realities and values and creating pressure for reform” in Ontario.17

Human rights historians have noted that the most vocal advocates for post-Second World War human rights reform were the victims of oppression themselves. The efforts of individuals and groups to push for change and mobilize against the discriminatory practices and beliefs of the state and society would prove to be a powerful impetus for change. By the 1950s, civil liberties associations, ethno-cultural associations, religious groups and organized labour groups became useful allies for minority rights advocates.18 It would take the combined efforts of these advocacy groups to convince the Ontario government to enact legislation that included a rights enforcement mechanism. Collectively, these groups emerged as the leading force behind the human rights movement, which would continue to gain strength in the 1960s and 1970s.19 They were spurred on by Canada’s international commitments to human rights policies and used these obligations to exert pressure on the state. The human rights advocates developed an incremental strategy that pressured Queen’s Park for reasonably attainable changes. Once Queen’s Park responded to these advocacy groups, further pressure was applied for more comprehensive change.20

While fair practices legislation propelled Ontario’s human rights policy forward, scholars have noted that they lacked effective enforcement mechanisms and were, therefore, largely ineffective in combating discrimination. Ontario judges were initially reluctant to conceive of discrimination as a criminal act. Additionally, many people – including the minorities that some of these laws sought to protect – were unaware of new legislation. Although the legislation reflected progressive steps towards increased equality, it fell short of actually forcing change in the province.21

Despite its shortcomings, this early anti-discrimination legislation represented a significant transformation in the role of the state and its ability to intervene on behalf of minorities. Public discourse and awareness regarding rights was broadened greatly across Canada when, in 1960, John Diefenbaker’s government enacted the Canadian Bill of Rights.22 Ontario’s rights revolution moved forward significantly in March 1961 when the province created the country’s first human rights commission.23 Ontario’s Human Rights Commission (OHRC) was tasked with administering what would become Ontario’s first Human Rights Code. Bill 54 – An Act to establish the Ontario Code of Human Rights and provide for its administration – was an expansive statute prohibiting discrimination on numerous grounds in accommodations, services and employment. First introduced by the Minister of Labour – the Honourable W.K. Warrender – in December 1961, Bill 54 sought to consolidate previously separate fair practice laws into the Ontario Human Rights Code. The Code came into effect on June 15, 1962 – the anniversary of the signing of the Magna Carta in 1215. It was one of the first pieces of legislation that Premier Robarts introduced on assuming leadership of Ontario’s government. The Code’s influence was widespread; by 1977 every jurisdiction in Canada had a code and a full-time human rights commission.24

The intent of the Code is defined in its ‘Preamble,’ which states that all people: have human rights that cannot be infringed upon or dismissed; have individual dignity and worth; are entitled to equal rights and opportunities without discrimination, and; need a climate of understanding and mutual respect so that everyone feels a part of society and can contribute fully to it.

The Code was more than a consolidation of separate fair practice laws; it mandated the Ontario Human Rights Commission, with a mandate to administer a complaint and compliance procedure and initiate programs to educate the public about new legislation.25 The Commission was responsible for advising the government on the future development of the Code with the goal of forwarding the cause of equality policy in the province and was assigned a full-time Director, staff and a permanent office.26 Dr. Daniel Hill was the first Director of the OHRC.27 Under the leadership of the commission, discrimination issues gained a much greater public profile and were being placed, and tackled, within the context of larger systemic social inequalities. Perhaps most significantly, victims of discrimination could now come forward and employ a state mechanism to substantiate and investigate their claims.28

Ultimately, the Code widened justice and democracy in Ontario. Moving forward, the Code continued to evolve – giving legal meaning to the values of dignity, equality and respect. In 1965 there were four amendments passed to cover all agencies of the provincial government and to amend the language covering housing and commercial spaces.29 Additionally, in 1966 the Age of Discrimination Act was passed and the Commission was entrusted with administering it.30 Dr. Daniel Hill worked diligently to advocate for future protections under the Code. In 1969 he outlined how and where within the Code increases in use by specific groups were occurring – for example, by Aboriginals, recent immigrants and women – and suggested areas where it could be improved.31

Additionally, widespread improvements to civil rights in Ontario resulted from a Royal Commission Inquiry into Civil Rights – held between 1964 and 1971 – led by former Chief Justice of Ontario James McRuer. The resulting “McRuer Report” made almost 1,000 recommendations aimed at bringing laws into conformity with then current standards of civil rights.

Between 1975 and 1977 a major review of the Code was undertaken by the OHRC, under the leadership of its Chair Thomas H.B. Symons32, in order to address existing limitations within the Code and to keep pace with the province’s changing human rights needs. An unprecedented 17 public consultations were held across the province and more than 300 written briefs were submitted. The resulting report, titled Life Together,33 contained 100 recommendations, ranging in subject from the expansion of grounds of discrimination – to include, for example, disability, family status and sexual orientation – to the need for adequate resources so that the OHRC could properly fulfil its mandate. As recommendations were acted upon over subsequent decades, the Code and OHRC adopted the modern, inclusive, active approach to human rights that they exhibit today.

This tradition of improving and strengthening Ontario’s Human Rights Code has continued as the government – spurred on by the continued efforts of advocacy groups and individuals – has worked to act as a provider and protector of human rights.34 Today, the Code continues to respond to social change while remaining true to its core and defining values of justice and equality. In so doing it continues to both shape, and be shaped by, the ways in which Ontarians perceive themselves as a people. In the tradition of those early advocates for human rights in Ontario, the Code itself, and the commission that administers it, has been guided by a combination of fortitude and flexibility – a combination that is essential to growth, health and progress the world over.

The Ontario Heritage Trust gratefully acknowledges the research of Amanda Robinson and Sam Wesley in preparing this paper.

© Ontario Heritage Trust, 2012

1 T.M. Eberlee and D.G. Hill, “The Ontario Human Rights Code,” The University of Toronto Law Journal 15, no. 2 (1964): 449.

2 The Honourable Arthur Roebuck, “Civil Liberties” speech delivered at the Chateau Laurier, Ottawa, May 5, 1946.

3 By then the economy was booming and the horrors of Nazi Germany’s racist policies and atrocities had appalled Canadians.

4 Peter Cumming and Neil H. Mickenberg eds. Native Rights in Canada (Toronto: Indian-Eskimo Association of Canada, 1972).

5 Canada’s 1867 Constitution did not guarantee equal rights despite the fact that it enshrined civil liberties. Dominique Clément, “’Rights without the Sword are but Mere Words’: The Limits of Canada’s Rights Revolution,” in A History of Human Rights in Canada: Essential Issues, ed. by Janet Miron (Toronto: Canadian Scholar’s Press, 2009), 46.

6 R. Brian Howe and David Johnson, Restraining Equality: Human Rights Commissions in Canada (Toronto: University of Toronto Press, 2000), 5; Brian Howe, “The Evolution of Human Rights Policy in Ontario,” Canadian Journal of Political Science/Revue canadienne de science politique 24, no. 4 (December 1991): 787.

7 Also in 1933, the Cooperative Commonwealth Party held their first national convention and adopted the ‘Regina Manifesto’ as their party program. The Manifesto called for “equal treatment before the Law of all residents of Canada irrespective of race, nationality or religious or political beliefs.” Constitutional scholar (and poet) F.R. Scott was one of the drafters of the Manifesto. He later became Dean of McGill law school and was a force in rights advocacy for

8 According to scholars, there were many reasons why discrimination was practiced and why the public did not support human rights legislation during this period. These attitudes and beliefs were responsible for discrimination towards minorities and women in social and economic ways – for example, employment – but also for a more formal and official type of discrimination carried out by the state. See Howe and Johnson, Restraining Equality, 4. For a more in-depth discussion of the ways in which discrimination was pervasive in society during this period, see Howe and Johnson, Restraining Equality; Clément, “’Rights without the Sword are but Mere Words’”; Ross Lambertson, “’The Dresden Story’: Human Rights, and the Jewish Labour Committee of Canada,” Labour/Le Travail 47 (Spring, 2001): 43-82.

9 According to R. Brian Howe, during this period there was a socially accepted laissez-faire approach to discrimination. That is, non-discrimination was understood as an ideal requiring individuals to act in non-discriminatory ways voluntarily. Sometimes this approach found favour even among minority leaders and ethno-cultural organizations. During the 1930s, Ontario’s Jewish community was sometimes reluctant to campaign for human rights legislation. They preferred to promote self-help, feeling that pressuring legislators may do more harm than good. Some in the Jewish community – and society in general – believed that racism was a problem best dealt with through a “friendly educational approach.” See Howe, “The Evolution of Human Rights Policy in Ontario,” 787. Additionally, Dominique Clément has noted that during this period the state traditionally favoured the discriminator. The rights to freedom of speech or association were interpreted as the right to refuse service to certain peoples or to express prejudicial ideas. See Dominique Clément, Canada’s Rights Revolution: Social Movements and Social Change, 1937-1982 (Toronto: UBC Press, 2008): 29-30. In a similar vein, Maxwell Yalden has written on the persistent tension between various individual and group rights on the one hand and freedom of expression on the other. See Maxwell Yalden, Transforming Rights: Reflections from the Front Lines (Toronto: University of Toronto Press, 2009); Howe and Johnson, Restraining Equality, 5.

10 During the course of the war only 5,000 Jews were permitted entry into Canada despite international pressure for Jewish refugee relief. Clément, “’Rights without the Sword are but Mere Words,’” 46.

11 Betcherman, Lita-Rose. The Swastika and the Rose (Toronto: Fitzhenry & Whiteside, 1975), 147.

12 Arnold Bruner, “The Genesis of Ontario’s Human Rights Legislation,” University of Toronto Faculty of Law Review 37 (1979), 238.

13 Article two of the Universal Declaration of Human Rights recognizes that, “everyone is entitled to the rights and freedoms set forth in this Declaration without distinction of any kind, such as race, colour, sex, language, religion, political or other opinion.” Lambertson, “’The Dresden Story,’” 49. Part of the Declaration was drafted by Canadian legal scholar John Humphrey.

14 Lambertson, “’The Dresden Story,’” 49. The human rights ideas that emerged in the 1940s took place alongside an international surge of egalitarianism ideals that the Second World War had spurred on. These ideals were not unique to Canada, as international response to the ideals of fascism and post-war standards of human rights spread across liberal democracies. As a result, it came to be accepted that it was the responsibility of the law to counter social
discrimination and provide the social right to equal opportunity. See Howe, “The Evolution of Human Rights Policy in Ontario,” 787; Clément, Canada’s Rights Revolution.

15 Rights would not be entrenched in the Canadian Constitution until the Charter of Rights and Freedoms was included in the 1982 repatriation of the Constitution.

16 Clément, Canada’s Rights Revolution, 25; Clément, “’Rights without the Sword are but Mere Words,’” 47.

17 Howe, “The Evolution of Human Rights Policy in Ontario,” 787.

18 Lambertson says that organized labour was a central element of the post-war Canadian human rights policy community. Lambertson, “’The Dresden Story,’” 47. This took place amid structural change in Ontario in the post-Second World War period. Immigrants – many of them minorities – flooded into the province in the midst of an emergent labour movement and while the number of women entering the paid workforce was growing. This helped to create a social basis for anti-discrimination legislation as the desire of politicians to gain the votes of union leaders, women and minorities increased. In turn, state actors put pressure on senior policy advisors within their parties to enact legislation addressing the concerns of these groups. Howe and Johnson, Restraining Equality, 9-11; Clément, “’Rights without the Sword are but Mere Words,’” 47-48.

19 The 1960s and 1970s witnessed the development of a strong human rights movement in Canada. Canadian civil liberties and equality rights organizations, propelled by increasing incidents of homegrown discrimination and a radicalized American civil rights movement, became better organized and more outspoken. This expanded their appeal among urban, middle-class Canadians. Behiels, “Canada and the Implementation of International Instruments
of Human Rights,” 162. In addition to Kalmen Kaplansky, prominent civil and human rights leaders of the era included Alan Borovoy, Ben Kayfetz, Sidney Midanik, Bromley Armstrong and Dan Hill.

20 Howe and Johnson, Restraining Equality, 11.

21 Dominique Clément has argued that the reality of this early anti-discrimination legislation – although it represented a step in the right direction – was that it fell short of forcing change. The Toronto Star reported in August 1961 – over a decade after the earliest anti-discrimination laws were passed in Ontario – that only two complaints had been sustained. In theory, the courts were in a position to act on discrimination, but the laws were weakly enforced; many
people were hesitant to embrace the new role of the state, which they saw as “legislating morality.” Clément, Canada’s Rights Revolution, 25; Clément, “’Rights without the Sword are but Mere Words,’” 48; Toronto Star (Toronto, Ontario), August 3, 1961.

22 The limitations of the Bill of Rights have been widely criticized. The need for more adequate rights protection at the federal level led to the Charter of Rights and Freedoms.

23 Howe and Johnson, Restraining Equality, 9.

24 Clément, Canada’s Rights Revolution, 28; Howe and Johnson, Restraining Equality, 9; Clément, Canada’s Rights Revolution, 55.

25 Conciliation, persuasion, and education were all perceived as vital to the Commission’s role in order for the process to work. If a victim of discrimination registered a complaint with the Commission, a human rights officer would investigate. If evidence supported a complaint, there would be informal efforts to bring complainant and respondent together to conciliate the dispute with amicable settlement. If this failed, tougher law enforcement would be pursued,
including fines. Howe and Johnson, Restraining Equality, 11.

26 Howe and Johnson have argued that in some respects the Code was a modest development in human rights law. Under the Code, discrimination was prohibited only on the most “basic grounds” and only in the most “fundamental areas.” Additionally, they have argued that the fines for violating the code have been miniscule. Howe and Johnson, Restraining Equality, 9-10.

27 Dr. Daniel Hill was born in 1923 in Missouri. He co-founded the Ontario Black Historical Society and completed his PhD at the University of Toronto in 1960. His doctoral dissertation, “Negroes in Toronto: A Sociological Study of a Minority Group,” along with his work with the Committee for the Adoption of Coloured Children stand as a testament to the important role he played in shaping race relations in Ontario and Canada. Daniel McNeil, “Ushering children
away from a ‘light grey world’: Dr. Daniel Hill and his pursuit of a respectable Black Canadian community,” Ontario History 99.1 (Spring 2007): 96.

28 Howe and Johnson, Restraining Equality, 9-11.

29 Michael Ignatieff, The Rights Revolution (Toronto: House of Anansi Press Limited, 2000), 2; Yalden, Transforming Rights, 118.

30 This was in response to the numerous complaints that the Commission received over age discrimination. McNeil, “Ushering children away from a ‘light grey world,’” 392.

31 McNeil, “Ushering children away from a ‘light grey world,’” 391-396. Clément has noted that it is critical to appreciate the limitations of the Code while also acknowledging that it represented a critical “building block” in the move to a modern human rights state. Although it conceived of rights it had no “provision for collective remedies” for discrimination. In addition to this, Dr. Daniel Hill and other scholars have acknowledged that despite the fact that the Commission was able to promote awareness, staff had to wait for complaints to be filed by individuals in order to act. See Clément, Canada’s Rights Revolution; Clément, “’Rights without the Sword are but Mere Words’”; Howe and Johnson, Restraining Equality; Daniel G. Hill, “The Role of A Human Rights Commission: The Ontario Experience,” The University of Toronto Law Journal 19 (Summer, 1969): 390-401.

32 Rosalie Abella. “Transformative Leadership: Tom Symons and a New Vision of Human Rights,” in Ralph Heintzman ed. Tom Symons: A Canadian Life (Ottawa: University of Ottawa Press, 2011).

33 Life Together: A Report on Human Rights in Ontario (Toronto: Ontario Human Rights Commission, 1977).

34 Advocacy groups continued to agitate for progressive changes. One such area of change was gender discrimination, as Ontario’s 1962 Human Rights Code did not acknowledge sex discrimination. According to Clément, none of the early anti-discrimination laws, including the Code in 1962, included provisions for protections. He also notes that, “early human rights campaigns simply did not prioritize gender.” Clément, “’Rights without the Sword are but Mere Words,’” 48. In the late 1960s a group of women working for General Motors launched a campaign against the company and the union (United Auto Workers) in order to have the Code amended to include the word sex. Their efforts were successful and in 1970 Bill 83 – An Act to Prevent Discrimination in Employment because of Sex or Marital Status – became law. The word ‘female’ was thus removed from collective agreements across Ontario. Historian Pamela Sugiman notes that their efforts significantly altered the gendered division of wage labour in the province and ultimately eliminated sex-based language from union contracts. See Pamela Sugiman, Labour’s Dilemma: The Gender Politics of Auto Workers in Canada, 1937-1979 (Toronto: University of Toronto, 1994).