Section 23 of the Canadian Charter of Rights and Freedoms is the section of the Constitution of Canada that guarantees minority language educational rights to French-speaking communities outside Quebec, and, to a lesser extent, English-speaking minorities in Quebec. The section may be particularly notable, in that some scholars believe that section 23 "was the only part of the Charter with which Pierre Trudeau was truly concerned." Trudeau was the prime minister who fought for the inclusion of the Charter of Rights in the Constitution of Canada in 1982. Section 23(1)(b), or section 23 as a whole, are also known as the "Canada clause." Text Under the heading "Minority Language Educational Rights," the section reads, Section 23 must be read in conjunction with Section 59 of the Constitution Act, 1982: History As a strong federalist, Trudeau had fought to ensure linguistic rights in the constitution to promote national unity. Section 23 (1)(b) had its origins in a unanimous agreement between the provincial leaders and Trudeau reached in 1978 in St. Andrews, New Brunswick, in which children of citizens could receive schooling in their language. When this idea was brought to the Charter in the 1980s, Trudeau also successfully secured agreement from provincial leaders that section 23 could not be nullified by the section 33 notwithstanding clause. When the government of Quebec had passed the Charter of the French Language in 1977, only parents who had gone to English schools in Quebec could have their children educated in English. Concerns for the erosion of the educational rights of English-speaking Quebeckers thus led to section 23(1)(b) being written so that that part of the Quebec law would become unconstitutional. This portion of the Charter of the French Language was indeed struck down by the courts in Attorney General of Quebec v. Quebec Protestant School Boards (1984). The verdict prompted the passing of Bill 86 in 1993 which amended the Charter of the French Language, stating that any child of a Canadian citizen whose parent or sibling had received English-medium education in Canada (rather than Quebec specifically) could attend English-medium schools. While there was decreased minority language education in Quebec at the time when the Charter was adopted, several other provinces (where English Canadians were the majority) had no French language schools at all. In contrast, in 2005 all provinces had minority language education schools. In 1986, 152,225 French Canadian students outside of Quebec