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37differential manner and was terminated because of her family status, contrary to section 7 of theCHRA.b) What approach is to be applied to determine whether there has been discriminationon the ground of family status?[145] The evaluation of whether there is discrimination on the ground of family status is carriedout according to the test set out in Public Service Labour Relations Commission v. BCGSEU,[1999] 3 S.C.R. 3 (“Meiorin”), just as it would be for any other prohibited ground ofdiscrimination. However, in recent years, the interpretation of the notion of “family status” hasled to the creation of two distinct schools of thought. Some cases have adopted a broad approachtowards the scope of “family status”, while other have taken a more narrow approach. In order tobetter understand what is included in the notion of “family status” we will review a certainnumber of these cases.2010 CHRT 22 (CanLII)[146] In Schaap v. Canada (Dept. of National Defence) [1988] C.H.R.D. No. 4, the Tribunal wasconsidering whether relationships formed in a common-law relationship as opposed to those in alegal marriage fell within the protected groups of “marital status” and “family status”. In itsdecision, the Tribunal found the need for a blood or legal relationship to exist and defined familystatus as including both blood relationships between parent and child and the inter-relationshipthat arises from bonds of marriage, consanguinity or legal adoption, including, of course, theancestral relationship, whether legitimate, illegitimate or by adoption, as well as the relationshipsbetween spouses, siblings, in-laws, uncles or aunts and nephews or nieces. In Lang v. Canada(Employment and Immigration Commission, [1990] C.H.R.D. No. 8, the Tribunal stated at page 3:“The Tribunal is of the view that the words “family status” include the relationship of parent andchild.”[147] In Brown v. Department of National Revenue (Customs and Excise), (1993) T.D. 7/93,the Tribunal held at pages 15 and 20:With respect to ground (b) [family status], the evidence must demonstrate thatfamily status includes the status of being a parent and includes the duties and