Section 6 of the Canadian Charter of Rights and Freedoms is the section of the Canadian Constitution that protects the mobility rights of Canadian citizens, and to a lesser extent that of permanent residents. By mobility rights, the section refers to the individual practice of entering and exiting Canada, and moving within its boundaries. The section is subject to the section 1 Oakes test, but cannot be nullified by the notwithstanding clause. Along with the language rights in the Charter (sections 16–23), section 6 was meant to protect Canadian unity. Text Under the heading "Mobility Rights", the section reads, Background Before the adoption of the Charter in 1982, mobility rights had existed by virtue of section 91 of the Constitution Act, 1867, which gave the federal government full jurisdiction over citizenship. Citizens were free to move across provincial borders and live wherever they chose to. Only the federal government could limit this right. This implied right was recognized by the Supreme Court in Winner v. S.M.T. (Eastern) Limited, where Rand J. observed: Aside from this, section 121 of the Constitution Act, 1867 allows for goods to be freely moved from province to province. Before the patriation of the Constitution in 1982 the governments considered extending this section to allow mobility rights for individuals. However, today the two sections are considered to be geared toward separate purposes. Section 121 remains concerned with keeping Canada economically united, and section 6 is primarily concerned with an individual's freedom of movement. The Supreme Court has compared section 6 to section 2(a) of the 1960 Canadian Bill of Rights, which bars "the arbitrary detention, imprisonment or exile of any person." However, section 6 expands on this right to also protect rights to leave and move within Canada. Purpose Along with the language rights in the Charter (sections 16–23), section 6 was meant to protect Canadian unity. French Canadians, who have been at the centre of unity debates, are able to travel throughout all Canada and receive government and educational services in their own language. Hence, they are not confined to Quebec (the only province where they form the majority and where most of their population is based), which would polarize the country along regional lines. According to the Supreme Court in Canadian Egg Marketing Agency v. Richardson (1998), section 6 is also "rooted in a concern with human rights." It allows for individual independence and