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Human Rights in Canada: An Historical Perspective

Theatre of the Absurd: War Abroad, Racism at Home

Lowe's Montreal Theatre
Montreal, Québec
January 26, 1918

Mr. Reynolds was a Renaissance man on a mission. He bought a ticket for an orchestra seat at the theatre. He never made it to his seat.

Mr. Reynolds was black, and the management of Lowe's Theatre said that "coloured" people weren't allowed to sit in the orchestra section. They were restricted to sitting in the mezzanine.This didn't sit well with Mr. Reynolds.

The ushers refused him entry and Mr. Reynolds took Lowe's to court.

Can you guess what happened?

Québec City, 1921

The Québec Court of Appeals ruled that the management of a theatre can make any seating rules it wants - even if these rules are discriminatory.

The Court also ruled that if the theatre had given Reynolds a special numbered and reserved seat, without any conditions attached to it, and he did not know that coloured people were barred from sitting there, then that would give rise to breach of contract. " All citizens of this country - white or black - are subject to the same laws and held to the same obligations."

Judge Carroll, dissenting from the majority decision in Lowe's Montreal Theatre Ltd. v. Reynolds

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Lowe's Montreal Theatre Ltd. v. Reynolds