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24[1999] 3 S.C.R. 3 (“Meiorin”), just as it would be for any other prohibited ground ofdiscrimination. However, in recent years, the interpretation of the notion of “family status” hasled to the creation of two distinct schools of thought. Some cases have adopted a broad approachtowards the scope of “family status”, while other have taken a more narrow approach. In order tobetter understand what is included in the notion of “family status” we will review a certainnumber of these cases.[93] In Schaap v. Canada (Dept. of National Defence) [1988] C.H.R.D. No. 4, the Tribunal wasconsidering whether relationships formed in a common-law relationship as opposed to those in alegal marriage fell within the protected groups of “marital status” and “family status”. In itsdecision the Tribunal found the need for a blood or legal relationship to exist and defined familystatus as including both blood relationships between parent and child and the inter-relationshipthat arises from bonds of marriage, consanguinity or legal adoption, including, of course, theancestral relationship, whether legitimate, illegitimate or by adoption, as well as the relationshipsbetween spouses, siblings, in-laws, uncles or aunts and nephews or nieces. In Lang v. Canada(Employment and Immigration Commission, [1990] C.H.R.D. No. 8, the Tribunal stated at page 3:“The Tribunal is of the view that the words “family status” include the relationship of parent andchild.”2010 CHRT 23 (CanLII)[94] In Brown v. Department of National Revenue (Customs and Excise), (1993) T.D. 7/93,the Tribunal held at pages 15 and 20:With respect to ground (b) [family status], the evidence must demonstrate thatfamily status includes the status of being a parent and includes the duties andobligations as a member of society and further that the Complainant was a parentincurring those duties and obligations. As a consequence of those duties andobligations, combined with an employer rule, the Complainant was unable toparticipate equally and fully in employment with her employer.[…]It is not suggested by counsel for the Complainant that the employer is responsiblefor the care and nurturing of a child. She was advocating however that there was a