Central Okanagan School District No 23 v Renaud

Central Okanagan School District No 23 v Renaud
Supreme Court of Canada
Hearing: Judgment:
Citations	[1992] 2 SCR 970
Docket No.	21682 [1]
Court membership
Reasons given
Unanimous reasons by	Sopinka J

Central Okanagan School District No 23 v Renaud, [1992] 2 SCR 970 is a leading Supreme Court of Canada decision where the Court found that an employer was under a duty to accommodate the religious beliefs of employees to the point of undue hardship.

Larry Renaud was a unionized custodian in the Central Okanagan School District and a practicing Seventh-day Adventist. Under a collective agreement, Renaud was required to work on Friday evening. However, Renaud's faith forbade him from working sundown on Friday to sundown on Saturday. He proposed several forms of accommodations in which he would work Sunday to Thursday as a religious exception to the collective agreement. The school board rejected the alternatives and eventually terminated his employment.

Renaud brought a complaint on the grounds the school board violated section 8 of the British Columbia Human Rights Act for discrimination based on religion. The issues put to the Supreme Court was whether Renaud had been indirectly discriminated against and whether the school was under any duty to accommodate him.

Justice Sopkina, writing for a unanimous Court, held that there had been discrimination against Renaud. Sopinka found that an employer was under a duty to accommodate employees religious beliefs short of undue hardship, even despite any collective agreement or private contract.

• Ontario (Human Rights Commission) v Simpsons-Sears Ltd
• Seventh-day Adventist Church

• Full text of Supreme Court of Canada decision at LexUM and CanLII