the provincial public health orders that prohibited in-person religious worship services in the face of the COVID-19 pandemic infringed on the freedom of religion. However, these courts ruled that this constitutional infringement was permissible in a "free and democratic society." Religious dress In a 1985 court case involving an employee of the Canadian National Railway, K.S. Bhinder, a Sikh whose religion required that he wear a turban, lost his challenge of the CNR policy that required him to wear a hard hat. In the 1990 case of Central Alberta Dairy Pool, the Supreme Court of Canada overturned the 1985 Bhinder decision, saying: "An employer that has not adopted a policy with respect to accommodation and cannot otherwise satisfy the trier of fact that individual accommodation would result in undue hardship will be required to justify his conduct with respect to the individual complainant. Even then the employer can invoke the BFOQ (bona fide occupational qualification) defence." In the 1991 case of Peel Board of Education v. Ontario Human Rights Commission, an Ontario school board's "zero tolerance" for weapons in its schools had an adverse impact on Khalsa Sikh men who are required by their religion to carry a kirpan, a ceremonial dagger. A Khalsa Sikh teacher brought a complaint under the Ontario Human Rights Code and was successful. The school board challenged this to the Ontario Divisional Court on the basis that there was a threat to public safety. The Divisional Court ruled that the threat to public safety from Sikhs was minimal and the discriminatory impact of the ruling on this religious group was significant. In 2006, the Supreme Court of Canada ruled in Multani v. Commission scolaire Marguerite‑Bourgeoys that Sikh children can wear a kirpan to school based on freedom of religion. In 1995, the Federal Court of Appeal upheld the exemption for Sikhs from wearing the "Mountie hat" as part of the RCMP dress requirements. In 2019, Quebec passed an Act respecting the laicity of the State that forbids public officials from wearing religious symbols or garb on the job and even denies public services to those wearing religious dress. Courts have found this bill to be egregiously unconstitutional, but continues to be enforce because the Quebec government invoked the notwithstanding clause, which temporarily allows some constitutional rights and freedoms to be infringed upon. Marital practice Prior to 1798, only ministers of the Church of England had