the authority to solemnize legal marriages in Upper Canada. This power was extended by degrees to religious officials of various other Christian denominations over the first half of the 19th century, until an 1857 act granted the power to solemnize marriages to the ministers of every religious denomination. A similar process occurred in Lower Canada, with the main difference being that it was the Roman Catholic Church which initially held the sole authority. Polygamous marriages, promoted by some religious minority groups, are illegal in Canada. Authorities often do not strictly enforce the applicable laws, as has been the case in Bountiful, British Columbia. On January 12, 2006, the Department of Justice (Canada) released a study, authored by three law professors at Queen's University, recommending that Canada repeal the laws that make polygamy a criminal offence. See related article, Polygamy and religion. In the 2003 case Halpern et al. v. Attorney General of Canada et al., the Ontario Court of Appeal rejected the argument that a failure of the law to recognize same-sex marriages violated the religious rights of the church that performed the ceremonies, though the court found the definition of marriage to be unconstitutional on other grounds. Refusal of service In 2000, a Board of Inquiry appointed under the Ontario Human Rights Code found that Scott Brockie, a Toronto printer, had discriminated on the basis of sexual orientation by refusing to print letterhead, envelopes, and business cards for the Canadian Lesbian and Gay Archives. The Board of Inquiry ordered Brockie to pay damages of $5,000 to the two complainants who had brought the complaint.Ontario (Human Rights Commission) v. Brockie, 2000 CarswellOnt 5474, 37 C.H.R.R. D/15. Brockie unsuccessfully appealed to Ontario Superior Court (Divisional Court) to overturn the decision. The divisional court ruled that the order requiring Brockie to print the materials was a justifiable violation of Brockie's religious rights. However, the court limited the scope of the Board of Inquiry's ruling to only ordinary material such as letterhead and envelopes. The court said the Board of Inquiry's order "ought not to require Mr. Brockie to print material of a nature that could reasonably be considered to be in direct conflict with the core elements of his religious beliefs."Ontario (Human Rights Commission) v. Brockie, 2002 CarswellOnt 2518 Ont. Sup. Ct. (Div.Ct.), para. 58. In 2002, the Rainbow Harmony Project, a choir that supports LGBT persons, filed a complaint against Camp