The appellant, a charity, operated camps at four locations in Ontario which were aimed at children of various age groups. Most of the paid staff were clergy. About 90 minutes per day were devoted to worship and religious teaching, with the balance of the day involving usual summer camp activities. In finding that the fees charged by the appellant were taxable by virtue of coming within para. 1(f), Malone JA stated (at paras. 24-25):
The English version excludes from the exemption any service by a charity, which involves supervision or instruction in any recreational or athletic activity. The appellant’s programme is one that involves the supervision or instruction of religious, athletic and recreational activities and therefore, is caught by the English version of paragraph 1(f). The text does not require that the recreational and athletic activity constitute the major component.
Similarly, the services offered by the appellant fall squarely within the French version of the text: religious instruction in the context of recreational and athletic activities.
In indicating that Camp Kahquuah (summarized here on "place of amusement" grounds, which were not at issue in this case) was incorrectly decided, he stated (at para. 33) that “it should not matter that the taxpayer’s underlying purpose was charitable.”