para. 55; R. v. Audet,  2 S.C.R. 171,  S.C.J. No. 61,
per La Forest J., at p. 196 S.C.R.
[ 62] As Dr. Glenn Watson observed in his Report of the Minis-
terial Inquiry on Religious Education in Ontario Public Elemen-
tary Schools (January 1990), at p. 57:
An educational system cannot be neutral. If there is no religious education
or any form of religion in the schools, then secular humanism, by default,
becomes the basic belief system. Secular humanism does not represent
a neutral position.
[ 63] He noted, at p. 50:
In every relationship, and especially in that between a teacher and a student, there is something that can be referred to as religious education. It is
the transmission of ideas, or answers to significant life-related questions, or
it is the exemplification of values by “precept and example.” There is no way
to avoid such an interaction and the learning experience associated with
that relationship over a period of time.
[ 64] The appellant’s intuition that teachers play a critical role
in inculcating beliefs in school children is amply supported.
( 4) Parental rights in education
[ 65] Education of the young is bound to be formative; if the
state educates the young, it also forms them, at least in part, and
perhaps the major part. However, the right of parents to care for
their children and make decisions for their well-being, including
decisions about education, is primary, and the state’s authority is
secondary to that parental right. This has been recognized in
many different cases, statutes and international instruments.
[ 66] The Charter protection of parental rights under s. 2(a) is
more broadly based than freedom of religion under s. 2(a) of
the Charter. Although the rights of parents to make choices for
the education of their children may be supported by religious
beliefs and practices, they are not conditional on religious
belief. They are equally protected under s. 2(a) as a matter of
[ 67] The law is clear that the authority of the state to educate children is a delegated authority: “Parents delegate their
parental authority to teachers and entrust them with the
responsibility of instilling in their children a large part of the
store of learning they will acquire during their development”:
R. v. Audet, at para. 41.
[ 68] The law recognizes the central role of parents in education, and their concomitant rights. In B. (R.) v. Children’s Aid
Society of Metropolitan Toronto,  1 S.C.R. 315, 
S.C.J. No. 24, at para. 223, the Supreme Court noted that
the “constitutional freedom [of religion] includes the right to