Andrews v Law Society of British Columbia, [1989] 1 SCR 143 is the first Supreme Court of Canada case to deal with section 15 (equality rights) of the Canadian Charter of Rights and Freedoms. The court outlined a test, sometimes called the "Andrews test", to determine whether there has been a prima facie violation of equality rights. Andrews further held that discrimination according to grounds analogous to those enumerated in section 15 could result in a violation of the Charter. History Andrews, a British subject and a permanent resident in Canada, met all the requirements for admission to the provincial bar with the exception he was not a Canadian citizen. Andrews brought a motion to strike down the requirement for citizenship on the grounds it violated section 15 of the Charter. At trial, Supreme Court of British Columbia held in favour of the Law Society. On appeal to the British Columbia Court of Appeal, the ruling was overturned. Joseph Arvay argued the case for the Attorney General of British Columbia. Judgment The problem put to the court was whether the requirement of Canadian citizenship for admission to the British Columbia bar is an infringement upon or denial of the equality rights guaranteed by section 15(1) of the Charter, and if so, whether it is justified under section 1. The majority of the court held that section 42 of Barristers and Solicitors Act violated section 15 and it could not be saved under section 1. The majority was written by Wilson J with Dickson CJ and L'Heureux-Dubé J concurring. In dissent, McIntyre and Lamer JJ disagreed on the point of the section 1 analysis, believing it would be upheld on the basis of "reasonable limit" and preferred to be deferential to the House of Commons. La Forest J wrote a separate decision. However, all three decisions adopted the section 15 analysis used by McIntyre J. The test set out by McIntyre J and adopted by the majority held that claims under section 15 would be assessed based on: Actual differential treatment, Based on one of the enumerated prohibited grounds in s 15 or one that is analogous to those grounds, Which is discriminatory because of an imposed burden or denied benefit. Reasoning The court first defined a general approach to the equality guarantee. The court stated that the section is not a general guarantee of equality, rather it is only concerned