3(1) forbids discrimination on prohibited grounds by actors that fall under federal jurisdiction, such as television, and federally regulated industries. Canadian provinces have their own human rights legislations that can be explicit as to the notion of reasonable accommodation. In Manitoba, section 9(1)(d) of the Human Rights Code defines discrimination as a "failure to make reasonable accommodation for the special needs of any individual or group if those special needs are based upon" prohibited grounds. These provincial legislations oblige actors under their jurisdiction (employers, service providers and landlords) to respect the duty to accommodate, to preserve a multicultural society. The particularity of the duty to accommodate on religious grounds is that cases fall both under the jurisdiction of the Charter and other federal and provincial human rights acts and that they challenge the notions of social values, secularism and gender equality. Definition The notion of reasonable accommodation is a judicial creation. It implies that "federal/provincial/territorial anti-discrimination measures place a positive duty on employers, service providers and landlords [...] to accommodate people's needs for reasons associated with recognized discriminatory grounds." According to Sandra Fredman, the duty of reasonable accommodation "represents and advance towards substantive equality" for three reasons. Firstly, "equality is explicitly asymmetric, aiming to redress disadvantage even if this entails different or more favourable treatment." Secondly, it is focused "on modifying the environment to facilitate the participation of those affected." Finally, "[it] goes beyond other conceptions of equality in that it expressly imposes a positive duty to make changes." The notion of reasonable accommodation is directly related to the freedom of religion. Indeed, in 2006, "the Multani decision [...] moved reasonable accommodation from the realm of employment law into a broader legal discourse on religious freedom more generally." In claims concerning discrimination on religious grounds, the burden of proof shifts to the employer, landlord or service provider who has to prove the two elements: (1) that the rule is necessary and (2) he accommodates the individual to the point of undue hardship. Limits The duty of reasonable accommodation on religious grounds experiences some limits, because all rights are not absolutes. Indeed, reasonable accommodation requires a balance between the rights of the claimant and the holder of the duty to accommodate. The main limit to the duty to accommodate that is included in the CHRA is the notion of undue hardship. It signifies that the discriminatory practice can be justified if