In Canada, the coming into effect of Section 15 of the Canadian Charter of Rights and Freedoms in 1985 saw a shift in the gay rights movement in Canada, as Canadian gays and lesbians moved from liberation to litigious strategies. Premised on Charter protections and on the notion of the immutability of homosexuality, judicial rulings rapidly advanced rights, including those that compelled the Canadian government to legalize same-sex marriage. It has been argued that while this strategy was extremely effective in advancing the safety, dignity and equality of Canadian homosexuals, its emphasis of sameness came at the expense of difference and may have undermined opportunities for more meaningful change.