At the time of Confederation there were three kinds of separate schools in Canada: for special linguistic groups, special racial groups, and special denomination groups (really a dual-confession Protestant-Catholic division). Despite a long tradition of French education in Manitoba, the province got no special protection from the British North America Act when it entered Confederation in 1870 because it had no statutory provision for public schools. There is, indeed, little evidence that French was officially a language of instruction in Manitoba with any constitutional guarantees. Nevertheless, there was a legal vacuum which was filled by French Catholic Schools. Legal uncertainties and national crises have permitted this situation to continue, and recently (1967) the Province in Bill 59 has made French a language of instruction in certain public schools. [J. M. Bumsted]