Religion in the Canadian Workplace: Still Possible

By George Waggott, founder, George Waggott Law

Many people have a misconception that there is absolutely no place for religion in the workplace. A recent decision by the Alberta Human Rights Tribunal is a reminder that workplace discrimination claims must show more than ideological disagreement — they must demonstrate real harm by the person filing the complaint.

In Perkins v Calgary Police Service, 2025 AHRC 64, the Tribunal dismissed a complaint brought by a Calgary police officer, Edward Perkins, who alleged that his employer failed to provide a religiously neutral workplace.

Mr. Perkins is an atheist, who claimed that he took issue with three separate events involving religious content: a prayer during a 2020 memorial service, a Catholic Elder’s blessing at a committee meeting, and a 2021 presentation by a Catholic organization. The evidence did not suggest any coercion or attempt to convert anyone present into believing in any particular view. Instead, these events appeared to be brief moments of respectful reflection, which each admittedly had a religious component.

Following the intake of the complaint, the case was dismissed on an administrative basis. In its decision, the The Tribunal upheld the original dismissal of the complaint, finding it had “no reasonable prospect of success” and should be addressed through the applicable collective agreement grievance process instead.

No Adverse Impact, No Discrimination

Crucially, the Tribunal found that Mr. Perkins had not met the threshold for establishing a prima facie case of discrimination. While it accepted that his atheist beliefs were a protected characteristic under Alberta’s human rights legislation, it concluded there was no evidence of any adverse employment-related impact.

“The complainant remains employed with the respondent,” the decision noted. “Beyond his objection to the reference to prayer at these events, he has not indicated any impact on his employment.” The events in question were all voluntary, and there were no employment repercussions for the employee’s objections. As a result, there was no basis to find discrimination in employment.

Charter Arguments Rejected

In his human rights case, Mr. Perkins also argued that the Calgary Police Service had breached its duty under the Charter of Rights and Freedoms to maintain religious neutrality in the workplace. On this point, the Tribunal’s decision was clear: its mandate is not to enforce the Charter broadly, but to determine whether a specific individual has experienced discrimination. As a result, it found no such discrimination and declined to accept the claims of Charter rights being breached.

Procedural Issues Dismissed

The case also included further allegations of procedural unfairness in how the complaint was handled, with Mr. Perkins arguing that recent changes to the Alberta Human Rights Commission’s process — including quicker screening and fewer full investigations — deprived him of the opportunity to gather supporting evidence. The Tribunal found no merit in this argument, noting that there was a failure to identify any specific evidence that was missing or show how the process caused prejudice.

Grievance Process the Better Path

Even if Mr. Perkins. had established the elements of discrimination, the Tribunal said it would still have declined to hear the case, since the issue is better handled through the collective agreement grievance process. In fact, the Calgary Police Association filed a policy grievance in 2023 alleging a lack of religious neutrality and Christian bias in the chaplaincy program.

This ruling reinforces a key workplace law principle: for unionized employees, internal grievance processes are often the more appropriate forum for resolving these kinds of disputes. The decision also highlights the fact that not every religious event or occurrence in the workplace is improper under Canadian law.

For more information about George Waggott Law, please see: www.georgewaggott.com, or contact: george@georgewaggott.com