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School prayer in its common usage refers to state-approved prayer by students in state schools. Depending on the country and the type of school, organized prayer may be required, permitted, or prohibited. Countries which prohibit school prayer often differ in their reasons for doing so: In the United States, school prayer is proscribed in accordance with Establishment Clause of the First Amendment to the United States Constitution (which provides the foundation for the separation of church and state); In Canada, school prayer is disallowed under the concept of Freedom of conscience as outlined in the Canadian Charter on Rights & Fundamental Freedoms Simultaneously, school prayer is disallowed in France as a byproduct of its status as a laïcist (religiously neutral) nation. Countries that allow school prayer include Greece, Iran, and the United Kingdom.

United States
In the United States, public schools are banned from conducting religious observances such as prayer. The legal basis for this prohibition is the First Amendment to the United States Constitution, which requires that Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof... The first part of the above amendment which reads “Congress shall make no law respecting an establishment of religion” is known as the Establishment Clause, while the second part (“or prohibiting the free exercise thereof”) is known as the Free Exercise Clause of the First Amendment. Though each of these clauses originally applied only to the central US government, the Fourteenth Amendment extended the scope of the entire First Amendment to all levels of government, including the state level —thus compelling states and their subject schools to adopt an equally detached approach to religion in schools.

School Prayer Prior to 1962
The issue of school prayer has been debated in the United States since the early 1900s. In the 18th, 19th and early 20th centuries, schools in certain localites of the country customarily opened with an oral prayer or Bible reading. Religious minorities would sometimes object to the distinct observations performed in the local schools. For instance, in the Edgerton Bible Case (Weiss v. District Board (1890)), the Wisconsin Supreme Court ruled in favor of Catholics who objected to the use of the King James Bible in Wisconsin public schools. This ruling was based on the state constitution and only applied in Wisconsin, but, like other challenges elsewhere in the country, provided a precedent for federal rulings to come later. The legal climate for school prayer in the US began to change in 1955, when the New York Board of Regents developed a prayer recommended (but not required) for the school districts under its purview. Seven years later, Steven I. Engels would bring action against Union Free School District No. 9 for its adoption and subsequent prescription of the so-called "Regent's prayer," arguing that it constituted the state-sponsored establishment of religion in violation of citizens’ First Amendment rights via the Fourteenth Amendment. Use of the Regents’ prayer would be initially upheld in both New York State Court and in the New York Court of Appeals, prompting Engel's to petition the US Supreme Court.

1962 and After
In two landmark decisions, Engel v. Vitale (1962) and Abington School District v. Schempp (1963), the US Supreme Court established what is now the current prohibition on state-sponsored prayer in schools. While the Engel decision held that the promulgation of an official state-school prayer stood in violation of the First Amendment’s Establishment Clause (thus overruling the New York Courts’ decisions), Abington held that Bible readings and other (state) school-sponsored religious activities were prohibited. Following these two cases came the Court's decision in Lemon v. Kurtzman (1971), a ruling that established the Lemon test for religious activities within schools. The Lemon test states that in order to be constitutional under the Establishment Clause of the First Amendment any practice sponsored within state run schools (or other public, state sponsored activities) must adhere to the following three criteria :


 * 1) Have a secular purpose;
 * 2) Must neither advance nor inhibit religion; and
 * 3) Must not result in an excessive entanglement between government and religion.

Controversy
Reactions to Engel and Abington were widely negative, where many school districts and states have attempted to reestablish school-sponsored prayer in different forms since 1962. Since the 1990s, controversy in the courts has tended to revolve around prayer at school-sponsored extracurricular activities. Examples can be seen in the cases of Lee v. Weisman (1992) and Santa Fe Independent School Dist. v. Doe (2000), where public prayers at graduation ceremonies and those conducted via public address system prior to high school games (at state school facilities before a school-gathered audience) were, respectively, ruled unconstitutional.

Despite their attempts to present a clear stance on school-sponsored religious activity, Engel, Abington, and the cases for which these serve as precedent are cited by some proponents of school prayer as evidence of a contradiction between the Establishment and Free Exercise Clauses of the First Amendment. While the Establishment Clause proscribes the state-sponsorship of religion, the Free Exercise Clause forbids state interference in individual religious exercise. Where a state entity moves to accommodate the right to individual religious expression under the latter clause, opponents of that “expression” may cite such accomodation as state “promotion” of one religious activity over another. Regarding the Free Exercise Clause, the courts have consistently stated that students' setting forth of religious views through prayer cannot be forbidden unless such activity can be shown to cause disruption in the school, yet it remains beyond the scope of the state to require such practice

British Columbia
Prior to 1944, in British Columbia, the Public Schools Act (1872) permitted the use of the Lord’s Prayer in opening or closing school. In 1944, the government of British Columbia amended the Public Schools Act to provide for compulsory Bible reading at the opening of the school day, to be followed by a compulsory recitation of the Lord’s Prayer. This amendment appeared as section 167 of the Public Schools Act, and read as follows:

"167. All public schools shall be opened by the reading, without explanation or comment, of a passage of Scripture to be selected from readings prescribed or approved by the Council of Public Instruction. The reading of the passage of Scripture shall be followed by the recitation of the Lord’s Prayer, but otherwise the schools shall be conducted on strictly secular and non-sectarian principles. The highest morality shall be inculcated, but no religious dogma or creed shall be taught. 1948, c.42, s.167"

The compulsory nature of the Bible reading and prayer recitation was slightly modified by regulations drawn up by the Council of Public Instruction. These regulations provided that either a teacher or student who has conscientious ground for objecting to the religious observances may be excused from them. The procedure to be followed in such cases was outlined in the regulations, which follow in full:"Division (15)—Scripture Readings (Section 167)" "15.01 Where a teacher sends a written notice to the Board of School Trustees or official trustee by whom he is employed that he has conscientious objections to conducting the. ceremony of reading prescribed selections from the Bible and reciting the Lord’s Prayer (as provided by Section 167 of the Public Schools Act), he shall be excused from such duty, and in such case it shall be the duty of the Board of School Trustees or official trustee concerned to arrange with the Principal to have the ceremony conducted by some other teacher in the school, or by a school trustee, or, where neither of these alternatives is possible, by one of the senior pupils of the school or by some other suitable person other than an ordained member of a religious sect or denomination."

"15.02 Where the parent or guardian of any pupil attending a public school sends a written notice to the teacher of the pupil stating that for conscientious reasons he does not wish the pupil to attend the ceremony of reading prescribed selections from the Bible and reciting the Lord’s Prayer at the opening of school, the teacher shall excuse the pupil from attendance at such ceremony and at his discretion may assign the pupil some other useful employment at school during that period, but the pupil so excused shall not be deprived of any other benefits of the school by reason of his non-attendance at the ceremony."

In 1982, the Canadian Charter of Rights and Freedoms received royal assent. Section 2 of the charter guaranteeing freedom of conscience and freedom of religion trumped Section 167 of the Public Schools Act (1872). Sixteen years later in 1996, based on precedent that would be established in Ontario (1989), required recitation of the Lord’s Prayer as outlined in the Public Schools Act would be held to violate the Charter of Rights and Freedoms.

Ontario
The challenges to Christian opening and closing exercises occurred mainly in Ontario with the crucial case being fought in The Ontario Court of Appeal in 1988.

"Zylberberg v. Sudbury Board of Education (Director) The Ontario Court of Appeal ruled that the use of the Lord’s Prayer in opening exercises in public schools offended the Charters. 2(a). 1988. (1988), 65 O.R. (2d) 641, 29 O.A.C. 23 (C.A.). Education regulations did not require the use of the Lord's Prayer and there was an exemption provision. The Ontario Court of Appeal ruled that the regulation infringed religious freedom because schools could use only the Lord's Prayer rather than a more inclusive approach. The exemption provision actually stigmatized children and coerced them into a religious observance which was offensive to them."

The Ontario Court of Appeal was persuaded by the argument that the need to seek exemption from Christian exercises is itself a form of religious discrimination. The judges described as insensitive the position of the respondents that it was beneficial for the minority children to confront the fact of their difference from the majority.

Russow v. British Columbia
In 1989, Joan Russow challenged, in the British Columbia Supreme Court, the Public Schools Act (1872)’s requirement that in British Columbia all public schools were to be opened with the Lord’s Prayer and a Bible reading. The argument was similar to the Zylberberg case and the result was the same: The offending words in the Public Schools Act were removed as being inconsistent with freedom of conscience and religion guarantees in the Canadian Charter of Rights and Freedoms. Further following the Zylberberg case to strike down use of the Lord’s Prayer in schools, the British Columbia Supreme Court incorporated the Ontario Court of Appeal's decision in Zylberberg in its entirety. From 1871 to 1989, observance of school prayer had declined.

With the unfavorable court decision, the requirement for Christian morning exercises was replaced with the following clauses found in the School Act (1996) in British Columbia. "Conduct:" "76 (1) All schools and Provincial schools must be conducted on strictly secular and nonsectarian principles." "(2) The highest morality must be inculcated, but no religious dogma or creed is to be - taught in a school or Provincial school."

France
As a declared 'laicïst' (roughly 'religiously neutral', secular) state, France has no school prayers. Instead, public servants are advised to keep their religious faith private, and may be censured if they display it too openly. The French law on secularity and conspicuous religious symbols in schools goes beyond restricting prayer in schools and bans the wearing of conspicuous religious symbols by pupils in public primary and secondary schools.

Turkey
The predominantly Muslim country of Turkey is in the public sphere a strongly secular nation. In this regard, it is much like France, on whose system of laicism its founder Kemal Atatürk modelled the rules on religion when he reformed his country in the early 20th century. School prayer is therefore unknown, and suspected religious motivations can cause serious difficulties for public servants. Despite its primarily secular stance, however, courses of religion and morals (which are dominantly Islamic) are compulsory to all students during the last years of elementary and throughout high school. In these instances, various Islamic prayers and verses are both taught and tested for.

United Kingdom
In England and Wales, the School Standards and Framework Act 1998 states that all pupils in state schools must take part in a daily act of collective worship, unless their parents request that they be excused from attending. The majority of these acts of collective worship are required to be "wholly or mainly of a broadly Christian character", with two exceptions:
 * Religious schools, which should provide worship appropriate to the school's religion (although most religious schools in the UK are Christian.)
 * Schools where the Local Education Authority's Standing Advisory Council on Religious Education has determined that Christian worship would not be appropriate for part or all of the school.

Despite there being a statutory requirement for schools to hold a daily act of collective worship, many do not. OFSTED's 2002-03 annual report, for example, states that 80% of secondary schools are not providing daily worship for all pupils.

Arguments for and against school prayer
The issue of school prayer remains contentious even where courts such as diverse as those in Canada, the United States, Russia, and Poland attempt to strike a balance between religious and secular activity in state-sponsored arenas. Some arguments have held that religion in schools is both an effective sociomoral tool as well as a valuable means to psychological stability. On the opposing side, others have argued that prayer has no place in a classroom where impressionable students are continually subject to influence by the majority. The latter kind of claim holds that, to the extent that a public school itself promotes the majority religion, the state itself is guilty of coercive interference in the lives of the individual.

A Moment of Silence
Despite ongoing debate, there are some instances where religious freedom and secular stability have been temporarily balanced. In the United States, some administrations have introduced a "moment of silence" or "moment of reflection" in which a student may, if he or she wishes to, offer a silent prayer. The US Supreme Court decision in Wallace v. Jaffree (1984) held that a moment of silence in schools for the purpose of individual prayer or meditation constituted a valid application of the Free Exercise Clause, while a moment of silence for the clear intended purpose of a state-approved devotional activity constituted a violation of the Establishment Clause. In this same case, the issue of school prayer was further complicated by a distinction made between a public assembly attended by participants of their own free will, and a public event where attendance is legally required. A voluntarily attended Congress may open sessions with a prayer, but schools full of public pupils may not. Here the US Supreme Courthas been interpreted the issue as revolving around the degree of a government’s ability to indoctrinate its citizens. If it appears that participants at a state-sponsored event are more likely to influence the State itself, courts may treat prayer as “legislative prayer.” If, on the otherhand, the State is more likely to influence participants at its events, courts may treat prayer as “state-sponsored” prayer an thereby rule it unconstitutional.

Other Methods of Moral Instruction
A 1995 report by the ACLU concluded, of 70 countries surveyed, only 11 governements favored prayer in school, with the majority opposing the practice. Nonetheless, in light of standards similar to that of the Lemon test as well as general approval by some local populations, schools have continued to promote the moral education of their students through a variety of secular and legislatively restricted religious means. In Finland (where school prayer was viewed more favorably), students attended either a class in religion as determined by a minimum of three students or a class in general ethics and worldview studies. . In secular Turkey, however, primary schools include general ethical instruction with a partial emphasis on nationalism, social contribution, and world affairs. Turkish secondary education consists of a system of lycees among which religion is included.