Charter of the French Language (including the Canadian Charter of Rights and Freedoms); section 23 introduced the notion of "minority-language education rights". This opened another door to a constitutional dispute of Quebec's Charter of the French Language. Alliance Quebec, an anglophone rights lobby group, was founded in May 1982. It is mainly through this civil association that a number of lawyers have challenged the constitutionality of Quebec's territorial language policy. The Charter of the French Language has been strongly condemned and widely unpopular among most of English-speaking Canadians, who constitute the majority of Canadians but are a minority in Quebec. The Charter was criticised by
Section 23 of the Canadian Charter of Rights and Freedoms two changes were made to Manitoba's Public School Act (PSA) in 1966 and 1970 when French language instruction was once again recognized as an official language of instruction. Manitoba's minority French language instruction rights have developed since the introduction of the Charter and Section 23 to a point where they have allowed for the inclusion of a separate school board (La Division Scolaire Franco-Manitobaine DSFM) which is fully funded by the provincial treasury and operates throughout the Province. Significant with regards to the Province's (Manitoba) interpretation of section 23 is how the "number of Students" and not "mother tongue" is