The concept of "enumerated or analogous grounds" originated in the essential 1989 "Andrews" case to refer to personal characteristics that, when being the basis of discrimination, show the discrimination is unconstitutional under section 15. There are nine enumerated grounds explicitly mentioned in section 15, although they are not actually numbered. In practice, the enumerated grounds have been given liberal and broad interpretations. For example, discrimination on the basis of pregnancy has been ruled to be sex discrimination ("Brooks v. Canada Safeway Ltd.").