The individual appellants gave similar evidence concerning
the nexus between their religious beliefs and their objections to
providing medical services that are contrary to their beliefs in the
sanctity of human life. For them, providing a patient with an
effective referral to a physician who provides MAiD or an abortion
would be the same as performing the medical procedures themselves. It would make them complicit and would be sinful.
 Some of the individual appellants deposed that their religious beliefs would preclude them from prescribing or providing
some or all contraceptives, which they regard as morally wrong,
and that referring patients for such methods of family planning
would also be morally wrong.
 The appellants’ objections that compliance with the Policies
would make them complicit in moral wrong is supported by the
evidence of expert theologians and ethicists who deposed that
the act of referral is a form of direct cooperation in the act which
makes the physician complicit. As one, Dr. Daniel Sulmasy, put it,
for a religious physician, “[r]eferral is not just a morally neutral
 As noted above, the appellants object to a range of medical
procedures and pharmaceuticals. The evidence also demonstrates
that individual physicians have different levels of tolerance for the
steps required to connect a patient with an alternative provider of
the services or pharmaceuticals. In their written submissions, the
appellants stated that all of the members of the appellant organizations would be comfortable providing a patient with the phone
number for Telehealth. This appears to be a retreat from the
evidence in the Divisional Court, which suggested that at least
some appellants would regard this as complicity. In oral argument, counsel for the appellants stated that they would also be
comfortable with providing patients with the phone number for
the CCS. This, too, appears to be a retreat from the evidence
that some of the appellants would not be comfortable with
providing the phone number for the CCS to patients. The appellants also submit that the wording of the Policies could be made
“Charter compliant” through the addition of an option for an
objecting physician to connect the patient with “a resource”
as an alternative to providing an effective referral as currently
defined by the Policies.
Is the interference trivial or insubstantial?
 The College submits that there is no Charter infringement
because the interference with the appellants’ freedom of religion
is no more than “trivial or insubstantial”.