orthodox Jewish and Islamic schools' ability to enjoy this freedom. Following a general change in attitudes within the Netherlands there has been controversy surrounding balancing the freedom of education with the other rights of non-discrimination that might be seen, particularly towards women in many conservative Islamic schools. Most religious schools in the Netherlands have also since stopped acting within their own subset of institutions, thus lessening their power within the education system. Combined with the growth in diversity, and an overriding importance of non-discrimination, the ability for religious groups with conservative views in the Netherlands to educate their children in the manner that they were has been tarnished. France On , the Constitutional Council ruled freedom of education was among the fundamental freedoms enschrined in the Constitution, basing on the 1882 Ferry Act. However, on August 13, 2021, even though some legal analysts posited this disposition would be overturned, the Council ruled it wasn't unconstitutional to submit homeschooling to a regime of authorisation. Situation in Europe (2013) A University of Amsterdam study of 2013 ranked six member states by their parallel education (the ability to voluntary create a religious denomination which can be aided/impeded through funding) to give an indication of the freedom of groups and individuals to instill their religious beliefs through education. The conclusions are listed below. Denmark Denmark achieved a high rating. Denmark’s constitution requires a duty of education, but not one aimed at the school. This creates an option for private education or home-school. Private schools receive a subsidy that covers approximately 3/4 of the costs. Over the last ten years, Denmark has raised its level of supervision of these schools and the obligations on the schools to regulate themselves. The Netherlands The Netherlands achieved a high rating; religious schools in the Netherlands which are private are funded equally to public schools and are subject to the same regulations. Well over half of the Netherlands' schools are built on the grounds of a religion. The Dutch constitution (article 23) protects freedom of education and means the government must hold private and state schools equally. While private schools need to employ proper teachers, they may select their teachers or pupils based on their spiritual beliefs or values. Ireland Ireland received a high rating. 95% of primary and 57% of secondary Irish schools are denominational, though this number is decreasing. Education is supported predominantly by Catholic but also