and a definition of equality. "Dignity requires respect, and respect is acknowledgment of human dignity." Another scholar identifies the same problem, arguing that harm to dignity is itself a type of harm, so it cannot be a factor in determining whether there has indeed been harm. Many criticisms levelled against the focus on human dignity point to inconsistencies in the Supreme Court's own definition of the term. Iacobucci J has variously characterized the term as referring to "personal autonomy and self-determination", "physical and psychological integrity and empowerment", as well as "self-respect and self-worth", indicating a conflation of different understandings of equality. One scholar notes that this confusion "[forms] a haphazard amalgamation and intermingling of dignity", and that it is a disservice to our understanding of equality by failing to distinguish between human dignity and human interest. Similarly, the Court has at times linked the concept of dignity with the imposition of disadvantage and prejudice while at other times linked it with the redress of discrimination. Substantially, the human dignity test has been widely criticized on the grounds that it sets a dangerous precedent for section 15 equality claims because its vague nature does not lend itself well to consistent and comprehensible application by the Court in the future, and because it puts forth a conception of equality that is formal rather than substantive. One scholar writes that "[t]he Courts' muddled and inconsistent application of human dignity suggests that it should be excised from Charter discourse altogether". In attempting to address these concerns and on the heels of the controversial Law decision, scholars proposed various alternatives to the human dignity test. It was widely accepted that the section 15 claims were inadequately addressed using the previous formulations following Andrews, yet the Court's decision in Law was seen as inadequately addressing these concerns. One writer argued the Court should replace the human dignity test with a "reformulated grounds approach focused on human vulnerability and concrete human interests" that would be focused on individual and group vulnerability and which would take into account of a variety of factors, including the four enumerated contextual factors of the human dignity test. Another proposed an increased focus on the concept of accommodation, as this should, in any case, be the central focus of any section 15 claim. Yet another critic of the human dignity test proposed an understanding of human dignity reformulated as a concept of