Since Jehovah’s Witnesses case SECTION 116 has been interpreted by the HCA on at least on three other occasions. In the case of Attorney-General (Vic) ex rel Black v Commonwealth (‘DOGS Case’) the High Court held that the funding did not contravene the establishment clause when the funding was for ordinary educational purposes. A majority held that the establishment clause only prohibited the Commonwealth from passing legislation that purposely created a national church or religion. Interpretations of the Constitution have made it clear that the government is able to offer support for religious groups, mainly by subsidising religious schools . In the Scientology Case the court had to determine whether The Church of
