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With the adoption of the Charter of the French Language by the Parti Québécois in 1977, Quebec Anglophones were most concerned about the erosion of their educational institutions resulting not only from the out-migration of Anglophones and Allophones to the rest of Canada (ROC), but also from the Bill 101 law stipulating that international immigrants to Quebec could no longer choose to send their children to English schools (Mallea, 1984). Thus, following Bill 101, Quebec Anglophones could no longer count on immigrants to maintain the demographic base necessary to keep open key English medium schools across the province (McAndrew, 2002). However by 1982, Anglophones, as English mother tongue “rights holders”, could now count on their right to English schooling in Quebec as enshrined in Article 23 of the Canadian Constitution.