"Prima Facia Discrimination: Is Tranchemontagne Consistent with the Supreme Court of Canada's Human Rights Code Jurisprudence?" 9 Journal of Law & Equality 33

Argues that the decision in Tranchemontagne to import a substantive test at the prima facia stage, into human rights tribunal cases, shifts the burden onto the claimant to prove that the rule was substantively discriminatory and is inconsistent with previous Supreme Court of Canada decisions.