This paper's purpose is to extensively review the historical understanding of conscience and the current juridical interpretation of freedom of conscience under section 2(a) of the Canadian Charter of Rights and Freedoms (1982). It then briefly notes that given the challenge faced by Ontario's Catholic schools in providing for inclusionary policies for gay students--in particular the provision of Gay Straight Alliance clubs, and the potential claim by Catholics to freedom of conscience under the Charter--it appears that litigation is inevitable.