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Manitoba History: Divided Minority: Franco-Manitobans and the Forest Case

by Emmet Collins
Department of Political Studies, University of Manitoba

Number 64, Fall 2010

This article was published originally in Manitoba History by the Manitoba Historical Society on the above date. We make this online version available as a free, public service. As an historical document, the article may contain language and views that are no longer in common use and may be culturally sensitive in nature.

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The year 1976 was a pivotal one for the French language in Canada. The Parti Québecois was elected in Québec, leading many to wonder whether the federation would survive. In Manitoba, an insurance broker received a parking ticket. This event, unremarkable in most circumstances, was significant because the recipient of the ticket, Georges Forest, successfully based a constitutional challenge on it. The Forest case, which began in 1975 and ended at the end of 1979, led to the re-establishment of French as an official language of Manitoba, 89 years after that status was revoked. Forest was fighting the provincial government for the rights of Manitoba’s Francophone minority. In spite of this, he faced considerable opposition from both the leadership of the Franco-Manitoban community and average Francophones.

Georges Forest (1924-1990), a co-founder of the Festival du Voyageur in 1970, helped to restore French as an official language in Manitoba after his battle over a unilingual parking ticket went all the way to the Canadian Supreme Court, in December 1979.
Source: Winnipeg Tribune Collection, University of Manitoba Archives & Special Collections.

Why were Franco-Manitobans so reluctant to support Forest? A brief history of the French language in Manitoba, including its legislative status and the attitudes of Francophones historically will set the scene. This section will also explain the lead-up to the Forest case and the case itself. The second section will explore the reasons for the division in the French community regarding the Forest case.

There are four main reasons for the division surrounding the Forest case. First, there were doubts about the legitimacy of the case. Second, when it became apparent that Forest intended to take the case to the Supreme Court, there was a fear that he might lose. Third, many Francophones feared that if they were too forceful in pressing for their rights, they would suffer a backlash from the Anglophone community. Finally, the personality of Georges Forest led some to oppose his case.


There is a relative lack of primary information sources regarding division in the community. To gather background details of the event, two main methods were employed. First, the archives of the French language weekly paper La Liberté, published in Winnipeg, were consulted for the period 1976 to 1979. Particular attention was paid to editorials and letters to the editor in order to evaluate attitudes regarding Forest and his case.

Second, interviews were conducted with four people from the Franco-Manitoban community. Raymond Hébert is a professor of Political Science at the Collège universitaire de Saint-Boniface and author of Manitoba’s French Language Crisis: A Cautionary Tale. The book chronicles both the Forest case and the crisis that followed it. Vincent Dureault is a broadcaster at CKSB in St. Boniface and actively supported Georges Forest from the start of the case. Claude Forest is the eldest son of Georges Forest and owner of a media insurance company. Rénald Rémillard is a lawyer and current director of the Institut Joseph Dubuc, which does research and training in French for law professionals in western Canada. All were interviewed in March 2009. All interviews were conducted in French and transcribed by the author into English.

A Brief History of (French) Manitoba

The first European settlers in Manitoba were the French voyageurs and coureurs de bois, fur traders from Montreal who worked for the North-West Company. They first began trading in what is now St. Boniface in the 1730s, nearly 75 years before the first Scottish and English settlers arrived in 1812. [1] For much of the 19th century, French, Anglo-Scottish and the majority Métis population lived in relative harmony, based on mutual tolerance and understanding. [2] This relative peace, however, was soon disturbed by the desire of the Canadian Parliament to annex Rupert’s Land. [3] The arrival of increasingly “… boisterous … Canadians who saw themselves as the creators of a new and superior order in the Northwest …” caused understandable anxiety among the French and Métis populations of the Red River Settlement (RRS). [4] As a result, the Métis, led by a young Louis Riel, established a strictly Métis “National Committee” that seized Fort Garry. They later formed a provisional government to oppose the incursions of the newly established Canadian government and, more specifically, to negotiate the entry of the RRS into Confederation. [5] The provisional government drew up four consecutive lists of rights, the last of which was used to negotiate the entry of the RRS into Confederation. Included among the rights were provisions for appointing bilingual Appeal Court judges and a bilingual lieutenant-governor, as well as a stipulation that “all Public Documents and Acts of the Legislature be published in both languages.” [6] Riel felt that he deserved to be called the father of Manitoba. However, his ordering of the execution of Ontarian Thomas Scott, a Protestant Orangeman, during the Riel Rebellion would later lead to his condemnation as a traitor and his own execution. [7] In the meantime, the Riel government did negotiate the entry of Manitoba into Confederation as a bilingual province in 1870. The Manitoba Act, the piece of federal legislation that brought Manitoba into confederation, contained Article 23, which mandated the use of French and English in the legislature, in the courts and in the documents emanating from either body (see Appendix 1). Article 23 is virtually identical to article 133 of the British North America Act, simply replacing the word “Québec” with “Manitoba.” [8]

Soon, however, legal requirements were superseded by demographic realities. In just five years the population of Winnipeg grew by 5000%. [9] This reflected a population boom in Manitoba and in Western Canada, the vast majority of which was coming from Ontario. [10] The result was that by 1890, Franco-Manitobans were a small fraction of the province’s population. The stage was set for two crucial acts of government: the abolition of dual, equally funded denominational schools and the Manitoba Official Language Act, which made English the only official language (see Appendix 2). The French community made a decision then that, of the two lost rights, education was the more important to pursue. [11] In fact, when in 1916 St. Boniface resident Joseph Dumas wanted to advance a challenge to the Official Language Act, he was persuaded by the leadership of the community to drop the case, since the important battleground was education. [12] Gerald Friesen explains that: “Because their children’s religious instruction was so important to them, because French might remain a language of instruction in the schools, and because they could establish a powerful political alliance with the English-speaking Catholics of Winnipeg, they chose to fight the school law rather than the language law.” [13]

The Official Language Act was found unconstitutional by a Manitoba judge in 1892, and again in 1909, 1976 and finally by the Supreme Court of Canada in 1979. [14] Nelson Wiseman claims that the Official Language Act “…was no administrative coup d’état: it simply mirrored the new demography.” [15] If the provincial legislature’s unilateral move to revoke the status of the French language does not constitute a coup d’état, then it is at least unconstitutional. Nonetheless, in what became the norm, the government of Manitoba simply ignored the verdicts and continued to do its business in English only. The compromise reached between Prime Minister Wilfrid Laurier and Manitoba Premier Thomas Greenway in 1897 allowed for classes to be taught in any minority language where numbers warranted. However, a series of articles in 1913 by the Manitoba Free Press exposing the lacklustre quality of minority language education brought the entire system back into question. [16] The Minister of Education at the time, R. S. Thornton, decided that the only solution was for bilingual education of any kind to be abolished. Thus, Franco-Manitobans lost that for which they had been prepared to sacrifice other language rights, the right to teach their children in their language. Though it was not illegal to teach in French, it was certainly not legal. [17]

La Survivance Franco-Manitobaine

In response to this denial of their constitutional rights, Franco-Manitobans created the Association d’éducation des Canadiens-Français du Manitoba, which assured a basic level of French education for the 50 years during which instruction in the language was banned. It is important to note that successive sympathetic administrations often turned a blind eye to the use of French textbooks and language in classrooms, and that senior bureaucrats “…waged a continuous battle against the more zealous school inspectors…” [18] The Franco-Manitoban community settled into a pattern of low-profile maintenance of their culture, what Frances Russell calls “la survivance franco-manitobaine” (Franco-Manitoban survival). During most of the following decades, until the Georges Forest case and even after, Franco-Manitobans were reluctant to speak out, and reacted harshly towards members of the community who did so.

From the mid-1950s, small steps were made towards reinstating French language education rights, first in specific subjects, then in entire grades, and finally, in 1970, to all grades. In 1968, the Société Franco-Manitobaine (SFM) was formed, and took on the mantle of the voice of Manitoba’s Francophone minority, a role it still plays today.

Edward Schreyer’s government, elected in 1969, was the first NDP government elected in Manitoba and it achieved a majority only with the support of St. Boniface MLA Laurent Desjardins. Francophones had great hopes for Schreyer’s progressive NDP government. In some ways, Schreyer delivered: it was under his government that French language education was legalized in all grades in Manitoba, and French and English were recognized as the official languages of instruction. [19] Progress was slow, however, and the trickle emanating from the government was nowhere near enough in the eyes of some, most notably Georges Forest.


Georges Forest was a Saint Boniface insurance broker with a reputation as an agitator. In March 1975, he received a parking ticket written only in English. He decided to fight it based on the fact that a unilingual ticket was in contravention of the City of Winnipeg Act, which stipulates that “All notices, bills or statements sent or demands made to any of the residents of St. Boniface community in connection with the delivery of any service, or the payment of a tax, shall be written in English and in French.” [20] For Forest, it was never a matter of the ticket itself; what he wanted was respect for the rights that he and others had fought to preserve in the amalgamation of Winnipeg. [21] Forest, who had gone on a hunger strike in 1971 to preserve the rights that Francophones had in St. Boniface, knew that without any pressure, the city would not (and did not) comply with language rights. [22] The first case ended inconclusively when the city attorney, who disagreed with Forest, requested clarification from then Attorney General Howard Pawley, who did not respond. [23] Forest received a second ticket in February 1976. Summoned to court in June 1976, Forest was told by a county judge that since the parking ticket was a judicial document, the provisions of the City of Winnipeg Act were superseded by those of the 1890 Official Language Act. This moment was a crucial one for Forest, because, in his own words, “I was now up against a statute which crushed the basic language rights granted Franco-Manitobans by the British North America Act of confederation itself.” [24] Forest appealed the decision and, in September 1976, the Official Language Act was ruled unconstitutional by Judge Armand Dureault in St. Boniface county court. [25]) The Schreyer government, in response, simply ignored the verdict, neither appealing it nor moving to repeal the Official Language Act, for obvious political reasons: the government could not be accused of capitulating to a minority. [26] The fact that Manitoba had successfully ignored Article 23 for 85 years meant that any move by Schreyer to rectify an injustice that only a few Francophones were complaining about would have been attacked by the Conservative opposition. In fact, in May 1977 Premier Schreyer announced he had “no intention of abrogating the 1890 law.” [27] This was consistent with the reaction of previous governments when the same verdict was issued in 1892 and 1909. The attitude of La Liberté on the matter was reflective of the attitude of many people regarding the Forest case:

“On ne peut en vouloir au Premier Ministre là-dessus. Il y aura des élections provinciales prochainement, et le français n’a pas gagné en popularité au Canada anglais ces temps derniers. On peut d’ailleurs, avant de s’insurger contre la déclaration du Premier Ministre, se demander quelle serait l’attitude d’un gouvernement conservateur en cette province sur cette question.” [28] [“We can’t expect much from the premier on the matter. Provincial elections are coming up, and French hasn’t grown in popularity over the past few years. Before we line up against this declaration by the Premier, we might ask ourselves what the attitude of a conservative government in this province might be on the matter.”]

Forest’s next step was to request the translation of four laws, which he was told could be done if he paid $50,000. [29] He sought an order forcing the government to comply with the Dureault verdict, and after considerable delays made his way to the Manitoba Court of Appeal in February 1979 (by this time the federal government had guaranteed funding for his case). [30] The Court of Appeal found the Official Language Act “ultra vires”— beyond its power to address. This was immediately appealed by the Sterling Lyon government. The Supreme Court agreed to hear the case at the same time as the Blaikie case in Québec, which dealt with the respect of the rights of that province’s Anglophone minority. On 13 December 1979, the Supreme Court ruled that the Official Language Act was indeed ultra vires, but remained silent on the consequences of that judgement. [31] Article 23 was restored, 89 years after it had been illegally abrogated. [32]

Throughout the case, Forest received only tepid support from the community. Even while Forest was in the Supreme Court, an ad hoc committee of the SFM warned of the possibility that victory might be hollow if the Lyon Conservatives were not compelled by the court to take specific action to respect Article 23 (this warning proved prescient in the short term). [33] The SFM supported Forest in theory, but was in reality quite sceptical of the case and the man, for a number of reasons.


Reaction to the legitimacy of the case itself can be categorized in two ways. First, there was the reaction on the part of the community, which was largely sceptical or downright hostile. Second, there was the reaction of the leadership of the community, that is to say the SFM.

Claude Forest argues that most Franco-Manitobans knew very little about the case, and that most of what they heard came from the side opposed to Georges Forest. With the SFM not embracing his case, Franco-Manitobans mostly did not have the opportunity to hear Forest’s opinion on the matter. La Liberté, at least in the initial period of 1976-1977, was far from supportive of Forest. Claude Forest calls La Liberté the “mouthpiece of the SFM”. It should be noted, though, that in 1978-1979, the paper was considerably more open to the case and made efforts to explain it in detail. In any case, even those who read La Liberté would not have had much opportunity to learn about Forest’s reasons for going forward with the case. The majority of Franco-Manitobans, however, read the English-language dailies, and through them learned the government’s position on the case. Without support, Forest became isolated. Perhaps the most prevalent opinion on the case was that it was a ridiculous affair, that Forest was tilting at proverbial windmills. The idea that a $5 parking ticket would lead to the re-establishment of the official status of French in Manitoba seemed farcical to many Franco-Manitobans, who knew little about the case. One can detect that sentiment in a letter to the editor in La Liberté from April 1978, in which the writer accuses Forest of being “un homme qui aime se voir et s’entendre parler à la télévision” [“someone who likes to see and hear himself talk on TV”], adding “Come on, Georges, déchausse tes raquettes, sort de la forest et paye ton tiquette.” [34] [“Come on Georges, take off your snowshoes, come out of the forest and pay your ticket”.] Further, Forest was breaking new ground: in 1976, the idea of advancing a court challenge to advance language rights was unusual. [35]

The SFM, for its part, was also sceptical, though for different reasons. In the beginning, Forest offered the case to the SFM. In his mind, this was a community case that the SFM, as the organization which represents Franco-Manitobans, should have accepted. [36] The SFM, according to Vincent Dureault, was listening to its lawyers, who cautioned that though Forest did have a case, it was far from a certain victory. Rénald Rémillard concurs, saying that the SFM did have some justification in doubting the case, since “there were very few decisions that might have indicated how the Supreme Court would rule on the case.” The SFM’s position on the legality of the matter stood in stark contrast to that of Forest, who was certain that he would be proven right. [37]

Moreover, Forest’s action was breaking a 90-year-old tradition of pushing for education rights. The education question had been the battleground Franco-Manitobans had been fighting for since 1890, and the SFM believed that education was the most important element. In an interview, La Liberté accused Forest of “[être] en train de soigner ce malade d’un mal de tête alors qu’il souffre d’un cancer” [“…trying to cure the Franco-Manitoban community of a headache when it’s suffering from cancer”], or, more pointedly, “…les besoins prioritaires actuels, pour lutter contre l’assimilation, sont peut-être autres que des droits juridiques” [38] [“The things we currently need to combat assimilation are possibly not judicial rights”.]. Irrespective of the legality of the affair, in the initial period of 1976 to early 1977, the SFM publicly doubted the validity of the case. The SFM’s president, Gérard Archambault, believed that Forest was pursuing theoretical rights with little practical application. [39] Even after Forest gained a significant victory in Saint-Boniface county court, Archambault characterized it as a “moral victory” that gave Franco-Manitobans “almost nothing.” [40] He later changed his wording, making the case that the SFM didn’t have the funds to support a case of that magnitude, and that it preferred to work at a local level. [41] Blay argues that because the SFM received its funding from the Secretary of State and had to justify its expenses to the federal government, it was unable to provide financial support from its own budget. [42]

It should be noted that in December 1976, the SFM created a special fund to support Forest’s initiative and claimed to be in moral support of the case. The organisation was never an enthusiastic supporter of Forest, however. It took until April 1978, two years after the start of the affair, for the SFM to publicly state that “the Forest affair is our affair.” [43] Even after Forest’s victory in the Manitoba Court of Appeal, in a case which was re-establishing the judicial and legislative rights of French in Manitoba, the SFM’s president declared that he saw no link between the case and the SFM. [44]


When it became apparent that Forest intended to pursue his case all the way to the Supreme Court, the SFM’s elite became concerned that he might not win. Raymond Hébert advances the idea that the SFM’s fear of Forest’s losing the case played a part in the organisation’s lukewarm support, saying “If he lost, he lost big and the whole community lost.” This idea is supported by the executive director of the SFM from 1976-1979, Raymond Poirier, who in a 1999 documentary wondered what might have happened had Forest lost. [45]

The fear was that if he lost, not only would Article 23 be largely invalidated, but all the small gains that had been made by the SFM and by bureaucrats would be lost. The concessions, most of which regarded education, had been hard fought, and the SFM felt that Forest was putting those advances at risk in the name of insubstantial rights. In the words of Vincent Dureault: “The SFM was being cautious. It was a lobby group that didn’t want to lose the little things the community had acquired; I think it’s that simple.” That same sentiment is expanded upon by Claude Forest, who argues that because the SFM’s leadership has traditionally been composed of educators and bureaucrats, the organisation has historically been risk-averse and lacked the entrepreneurial spirit needed to support the Forest case. Fear of losing what little had been acquired certainly led some to oppose Forest’s case.

The bottom line. The front-page headline in the Winnipeg Free Press of 13 December 1979 emphasized the financial cost of the Supreme Court decision earlier that day.

Fear and Loathing

Both Raymond Hébert and Frances Russell argue that the fear of a backlash played a large part in the division surrounding the Forest case. They attribute this to a desire to be “good neighbours”: “In pressing for respect of its rights, [the French community worried it] would raise the ire of the majority, which has either been ignorant of or antagonistic to these rights.” [46] Indeed, one can detect those sentiments in the words of one Grade Twelve Francophone student, who, when asked about language rights at the height of the 1983-1984 Manitoban French language crisis, responded, “I don’t know. I don’t want the English to get mad at the French.” [47] Hébert maintains that fear of a backlash is the single biggest reason for division over the case. Average Francophones had no desire to be targeted for the actions of one “radical”, and it was easier to be against Forest than to be on his side, particularly when Forest’s own message was so poorly transmitted. The minority situation of French-speaking Manitobans is never far from the collective mind of the community. The vast majority of Franco-Manitobans work with and are friends with Anglophones, and many of them are in mixed-marriages. Forest claimed to be advocating for the rights of the community and although today there is no hesitation to admit he was, at the time many people were wary of his claim. To many, Forest was someone who had proclaimed himself the saviour, and had done so without solicitation. In an editorial from February 1977, La Liberté editor-in-chief Jean-Jacques Le François accused Forest of “prétendre que lui seul, Georges Forest, détient la vérité, possède le secret, l’art de guider la francophonie de cette province vers une nébuleuse émancipation” [“...believing that he alone, Georges Forest, knows the truth, holds the secret, the art of guiding the French language in this province towards a nebulous emancipation”], adding “Personne, que nous sachions, n’a demandé à Monsieur Forest de se placer dans la situation oû il se trouve présentement.” [48] [“No one, that we know of, has asked Mr. Forest to put himself in his present situation.”]

Before the Forest case justified the legal status of French as an official language of the province, the position of French in public life in Manitoba was understood to be tenuous at best. The desire to not rock the boat was strong enough that some wished that Forest would leave well enough alone: the SFM’s president and executive director pleaded with Forest to drop the case. [49] Rénald Rémillard calls this extreme desire to maintain the status quo, however unsatisfactory, the psychological problem of being in a minority and believes that, to a lesser extent, this attitude is still present today. In the short term, fear of a backlash proved to be justified. The French language crisis of the 1980s proved the worst fears, bringing out a great deal of bigotry and intolerance. Forest himself suffered personally and professionally for his cause, receiving death threats and seeing an exodus of clients from his insurance brokerage, many of them Francophones. A rough estimate puts Forest’s lost revenue as a result of his case from 1975-1990 at a million dollars. [50]

Rémillard says that the fear was more than just one of backlash, however. The traditional battleground of education was a private one. While education is clearly publicly funded, it is intimately linked to family and culture. As such, asking for education rights is not particularly a matter of public interest. Forest was not content to just receive such “crumbs” in the private sphere. He wanted to make French a matter of public discourse, for French to take its place as an official language of the province. [51]


Georges Forest was a controversial man. As early as 1959, he brought attention to and vociferously opposed the uni-city project which made St. Boniface part of Winnipeg. He was involved in many different aspects of public life, as president of a local Caisse Populaire credit union, as a political candidate in local and federal politics, and as co-founder of the Festival du Voyageur. During those years, however, Forest developed a reputation. Within one year of the founding of the Festival, for example, Forest was forced out of the organisation. Hébert describes Forest as a “loose cannon.” [52] Asked to elaborate, he claims that Forest “was completely unpredictable...he did things his own way”. Forest’s personality certainly played a part in the division surrounding the case. His reputation as an agitator made many people in the community sceptical of the case; the parking ticket was seen as just another crusade. He was not afraid to speak his mind and made enemies in doing so. Le François of La Liberté called Forest pretentious, arrogant and presumptuous, while Forest accused the SFM of a flagrant lack of leadership and La Liberté of being irresponsible. [53] There was not only a clash of personalities between Forest and certain individual members of the Franco-Manitoban community, but between Forest and the larger attitude of the community, which Rémillard calls one of timidity.

Georges Forest was a man of deep conviction and passion for the French language. If his personality led to conflict with various people and organisations, it also gave him the strength to continue pursuing what he believed was right in the face of much opposition and intimidation. Where others might have dropped the case, Forest was committed to pursuing it to the end. According to Claude Forest, when the SFM’s leadership tried to convince him to drop the case, it galvanized him and was proof in his mind that he needed to keep going. The personality aspect of the Forest case is a double-edged sword. While he may have brought on more opposition than another person in the same position, his “uncompromising” nature allowed him to go forward. There can be no doubt, however, that the fact that it was Georges Forest pursuing the case led some Franco-Manitobans to oppose it.


The Forest case was a significant milestone not only for the Franco-Manitobans but for Manitoban politics and arguably Canadian politics. For example, the Court Challenges program which provides funds for Charter-based challenges to legislation was created as a result of actions like the Forest case and the Blaikie case in Québec. [54]

More generally, the desire of Franco-Manitobans to maintain the status quo fits what Jared Wesley has called Manitoba’s “middling” political culture. [55] This serves as a reminder that the Manitoban element of the term Franco-Manitoban is key to understanding the group’s culture and politics.

The Forest case can also serve as a warning against complacency. If Forest, under pressure from the community’s leadership, had dropped the case as Dumas did in 1916, the face of Manitoban politics might be different today. Even those who were against him in 1976 now admit that Forest was right, and that his victory was a significant one for the Franco-Manitoban community. Nelson Wiseman, who doubts the significance of political rights granted to Franco-Manitobans, admits that the symbolism of the victory is important. [56] The “middling” political culture that characterizes Manitoban politics, irrespective of language, can also lead communities to deliberately handicap themselves and prevent progress. This is especially important for minority groups, but can also be said of Manitoban society more generally.

Georges Forest also managed to at least partly drag Franco-Manitoban society out of its parochial and timid attitude. This attitude is still present to an extent today, but considerably less than it was 30 years ago. This is evidenced by the court challenges that followed Forest’s case and the disproportionately high political activity of a group that represents roughly 5% of the population of Manitoba. This research is a case study and is not meant to be generalized, but it seems likely that the repressed attitude evidenced by Manitoba’s French minority would be present in other minority groups such as Métis, First Nations or new immigrants, potentially limiting their political activism.


The Forest case faced opposition from most Anglophones (though of course not all), but more surprisingly from many Francophones. Forest’s case seemed absurd to many Francophones, who simply did not believe that a $5 parking ticket would wind up in the Supreme Court. The SFM, for its part, felt that Forest’s case dealt with a matter that did little to affect the material well-being of Francophones. The organisation also had doubts about whether Forest would win the case. Its leadership feared that if Forest lost, the community at large would lose the small gains that had been negotiated with the government. This fear was joined by one of a wider backlash from the Anglophone majority. Franco-Manitobans have historically been wary of rocking the boat and attracting too much attention to themselves. Finally, the strong personality of Georges Forest and his existing reputation in the community led some to disavow his case.

In the short term, the fears of a backlash were prescient. The Manitoba French language crisis of 1983-1984 was a traumatic event for many Franco-Manitobans and confirmed the worst fears. That event proved to be short-lived, however, and is unrepresentative of the present situation.

Thirty years after Georges Forest won his case in the Supreme Court, successfully re-establishing French as an official language in Manitoba, the importance of the case is recognized. Forest’s vision and determination are now valorized and respected in the French community, even by those who initially opposed him. Some put Forest on par with Louis Riel. Perhaps Forest’s most important legacy is the fact that he showed Francophones that they need not continue to fear taking their place in Manitoban society. Levels of assimilation rise and fall, but what remains of Manitoba’s Francophone population is proud to take its place alongside its Anglophone neighbours.

Appendix 1: Article 23 of the Manitoba Act (1870)

“Either the English or the French language may be used by any person in the debates of the Houses of the Legislature, and both those languages shall be used in the respective Records and Journals of those Houses: and either of those languages may be used by any person, or in any Pleading or Process, in or issuing from any Court of Canada established in the British North America Act, 1867, or in or from all or any of the Courts of the Province. The Acts of the Legislature shall be printed and published in both those languages.” (Cited from Hébert, 2004, page 8)

Appendix 2: The Manitoba Official Language Act (1890)

“AN ACT TO PROVIDE THAT THE ENGLISH LANGUAGE SHALL BE THE OFFICIAL LANGUAGE OF THE PROVINCE OF MANITOBA. HER MAJESTY, by and with the advice and consent of the Legislative Assembly of Manitoba, enacts as follows: English language in assembly and courts. (1) Any statute or law to the contrary [such as article 23] not withstanding, the English language only shall be used in the records and journals of the Legislative Assembly of Manitoba, and in any pleadings or process in or issuing from any courts in the Province of Manitoba. Statutes. (2) The Acts of the Legislature of Manitoba need be printed and published only in the English language. R.S.M. c.187 s.1. Act to apply only within the jurisdiction of this Legislature. This Act applies only so far as the Legislature has jurisdiction to enact.” (Cited from Blay, 1987, page 25)


1. Frances Russell, The Canadian Crucible: Manitoba’s Role in Canada’s Great Divide. Winnipeg: Heartland Associates Inc., 2003, p. 31.

2. Gerald Friesen, The Canadian Prairies: A History. Toronto: University of Toronto Press, 1984, p. 109.

3. Raymond Hébert, Manitoba’s French Language Crisis: A Cautionary Tale. Montreal and Kingston: McGill-Queen’s University Press, 2004, p. 5.

4. W. L. Morton, Manitoba—A History. Toronto: University of Toronto Press, 4th ed., 1979, p. 118.

5. Morton, p. 124.

6. Hébert, pp. 6-7.

7. Russell, p. 126.

8. Jacqueline Blay, L’Article 23. Winnipeg: Les Éditions du Blé, 1987, p. 16.

9. Morton, p. 169.

10. Russell, p. 133.

11. Ibid., p. 178.

12. Blay, p. 49.

13. Gerald Friesen, River Road: Essays on Manitoba and Prairie History. Winnipeg: University of Manitoba Press, 1996, p. 26.

14. Russell, 237, p. 259.

15. Nelson Wiseman, “Provincial Political Cultures” in Provinces: Canadian Provincial Politics. ed. Christopher Dunn, 21-56 (Peterborough: Broadview, 2nd ed., 2006), p. 27.

16. Blay, p. 40.

17. Russell, p. 194.

18. Ibid., p. 201.

19. Nelson Wiseman, “The Questionable Relevance of the Constitution in Advancing Minority Cultural Rights in Manitoba”. Canadian Journal of Political Science 25, no. 4 (1992): 697-721.

20. Russell, p. 235.

21. Claude Forest, interview with the author, March 2009.

22. Russell, p. 234.

23. Blay, p. 91.

24. Quoted in Russell, p. 236.

25. The irony of the situation is that the City of Winnipeg did have bilingual parking tickets available [Blay (1987), p. 92].

26. Hébert, p. 24.

27. Ibid., p. 25.

28. “Schreyer à l’AGA de la SFM”, La Liberté, 19 May 1977.

29. Hébert, p. 24.

30. Ibid., pp. 27-28.

31. Ibid., p. 33.

32. The Lyon government’s half-hearted and “legally miserly” attempt to rectify the 90-year-old injustice led to a further challenge, the Bilodeau case (Hébert, 2004, p. 33). The events surrounding that case, the attempt at creating a constitutional amendment by the Pawley government in the 1980s and the crisis that ensued are well covered by Blay, Russell and Hébert, and represent a disturbingly open discrimination, but are beyond the scope of this work.

33. Blay, p. 129.

34. Marcel Duchênes, letter to the editor. La Liberté, 20 April 1978.

35. Rénald Rémillard, interview with the author, March 2009.

36. Claude Forest, interview with the author, March 2009.

37. Blay, p. 114.

38. “Entrevue Avec Georges Forest”, La Liberté, 17 February 1977.

39. Blay, p. 96.

40. Ibid., p. 101.

41. Ibid., p. 97.

42. Ibid.

43. “L’affaire Forest c’est notre affaire”, La Liberté, 27 January 1977.

44. Bernard Bocquel, “Forest gagne en cour d’appel”, La Liberté 3 May 1979.

45. “L’affaire Forest—20 ans plus tard”, Le téléjournal Manitoba, Radio Canada, 13 December 1999.

46. Hébert, p. 24.

47. Russell, p. 365.

48. Jean-Jacques Le François, “Le Cas de Monsieur Forest”, Editorial, La Liberté 17 February 1977.

49. “L’affaire Forest—20 ans plus tard”.

50. Claude Forest, interview the author, March 2009.

51. Vincent Dureault, interview with the author, March 2009.

52. Hébert, p. 21.

53. La Liberté, 17 February 1977.

54. François Boileau, “The Court Challenges Program, Annual Report 1994-1995”. Winnipeg, Court Challenges Program Canada: 1995.

55. Jared Wesley, “Political Culture in Manitoba”. Draft Paper presented to the Duff Roblin Professorship Conference on Manitoba Politics, Government and Policy in the 21st Century, p. 1.

56. Wiseman, 1992, pp. 719-720.

Page revised: 5 October 2022

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