Oakes, at p. 138 S.C.R. This requires the identification of the
purpose of the requirements.
 The Divisional Court identified [at para. 146] the purpose
as “the facilitation of equitable [patient] access to [health care]
services”. This appears to be an amalgam of the purpose identified
by the appellants (“ensuring access to health care”) and by the
College (“the protection of the public, the prevention of harm to
patients, and the facilitation of access to care for patients in our
multi-cultural and multi-faith society”).
 The Divisional Court gave context to its description of the
purpose of the effective referral requirements, by characterizing
physicians as “gatekeepers” in a publicly-funded health care
system, with duties not to abandon their patients and to put their
patients’ interests ahead of their own. The court said, at para. 146:
As the CPSO notes, underlying this purpose [of the facilitation of patient
access to health care] is the context of a publically funded health care system
and a patient-centered environment. In this environment, physicians perform
a positive role for their patients as “gatekeepers” to health care services and
are subject to the obligation of non-abandonment, as well as the obligation to
put the interests of their patient ahead of their own. It is entirely consistent
with this environment and these obligations that the Policies seek to ensure
that the religious and conscientious objections of physicians do not become
a barrier to health care for patients who seek healthcare services to which
particular physicians may object.
 LEAF submits that the importance of promoting women’s
equality rights by facilitating equal access to health care should
also be considered in determining whether the objective of the
effective referral requirements is pressing and substantial.
 Although initially the appellants did not strenuously
challenge the Divisional Court’s statement of the purpose of the
effective referral requirements, their supplementary factum
adopts an argument of the intervenor, the JCCF, that the stated
purpose of the effective referral requirements is imprecise and too
broad, distorting the minimal impairment and balancing stages of
the Oakes analysis and immunizing the Policies from meaningful
scrutiny. Neither the appellants nor the JCCF propose an
alternative formulation of the purpose of the requirements.
 The College contends that the Divisional Court did not err
and the objective articulated is neither overbroad nor imprecise.
 In my view, the Divisional Court did not err in articulating the purpose of the effective referral requirements. The
Divisional Court struck an appropriate balance in identifying
a purpose that is more specific than the “animating social
value” of the Policies, but broader than a “virtual repetition” of the
effective referral requirements: see R. v. Moriarity,  3 S.C.R.
485,  S.C.J. No. 55, 2015 SCC 55, at para. 28. The purpose