with equal application of the law. It was further stated that it should be recognized that not all differences in treatment will result in inequality and that identical treatment may result in inequality. As such, the suggestion to apply the same legal rules to groups or individuals who are "similarly situated" ("similarly situated test" where likes are treated alike and dislikes differently) was firmly rejected. Bliss v Canada (AG), a pre-Charter Supreme Court case where a pregnant woman was denied employment benefits, was considered as an example of the problems with such an approach. Instead the court concentrated on the prohibition on discrimination. . . . discrimination may be escribed as a distinction, whether intentional or not but based on grounds relating to the personal characteristics of the individual or group which has the effect of imposing burdens, obligations, or disadvantages on such individual or group not imposed on others, or which withholds or limits access to opportunities, benefits, and advantages available to other members of society. Distinctions based on personal characteristics attributed to an individual solely on the basis of association with a group will rarely escape the charge of discrimination, while those based on an individual's merits and capacities will rarely be so classified. (p. 280) The court states the discrimination must be based on an "enumerated or analogous grounds", and the individual seeking to strike down a law must demonstrate the existence of differential treatment based on either of the two grounds. From there the onus shifts to the Crown who must show the law justified under s. 1. The majority found that the citizenship requirement was not strongly linked to a person's capabilities to practice law, and so found it in violation of section 1. Legacy Andrews was the leading case during the first decade of section 15 jurisprudence. By holding the phrase "in particular" in section 15 made the listed grounds non-exhaustive and recognizing citizenship as an analogous ground, the Court opened the door to include other historically marginalized groups that were not explicitly protected under that section such as members of Canada's LGBT community. In the 1999 case Law v Canada (Minister of Employment and Immigration), the Supreme Court tightened the Andrews test, limiting burdensome differences in treatment to those that a reasonable person would say violated the claimant's dignity as a human being. This position was reversed by the Supreme Court in the