The limitation on the deduction of child care expenses in s. 63 of the Act did not violate s. 15(1) of the Charter in the absence of evidence that women disproportionately pay child care expenses. However, Iacobucci J. noted (p. 6026) that:
"if, for example, it could be established that women are more likely than men to head single-parent households, one can imagine that an adverse effects analysis involving single mothers might well take a different course, since child care expenses would thus disproportionately fall upon women."