School prayer in its most common usage refers to state sanctioned prayer of students in schools. Depending on the country and the type of school, organized state sanctioned prayer may either be permitted or proscribed. If permitted, the school prayer may be a required activity or may be optional for students. If proscribed, school prayer may be restricted or banned outright. The separation of church and state, as in the United States, is one legal reason given for proscribing state sanctioned school prayers. Freedom of conscience, as in Canada, is another.

In the U.S., staff-sanctioned prayer in public schools was effectively outlawed by two landmark Supreme Court decisions: Engel v. Vitale [1962] and Abington School District v. Schempp [1963]. Following these two landmark cases came the Court's decision in Lemon v. Kurtzman [1971]. This ruling established the so-called "Lemon test" which states that in order to be constitutional under the Establishment Clause of the First Amendment any practice sponsored within public schools must: 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.

Regarding the Free Exercise Clause of the First Amendment, the courts have consistently ruled that students' expressions of religious views through prayer or otherwise cannot be abridged unless they can be shown to cause substantial disruption in the school. Reinstatement of state-sponsored prayer has been attempted in different forms in a number of areas of the U.S. Few areas allow oral prayer, but some introduced a "moment of silence" or "moment of reflection" when a student may, if he or she wishes to, offer a silent prayer.

Besides citing separation of church and state, some opponents question why children cannot simply pray during non-school hours, or during school hours but not as part of an organized, state-sanctioned activity.

Recently, some high schools have banned prayer from graduation ceremonies. In May 2006, the ACLU of Tennessee convinced Munford High School's principal to ban official prayer at graduation. [http://www.commercialappeal.com/mca/local/article/0,2845,MCA_25340_4719351,00.html] In response, students pulled out cards with the LordL-rd's Prayer written on them and began to read. Also, some have concluded that the school's ACLU club faculty adviser has lost her job over the incident. [http://www.commercialappeal.com/mca/local/article/0,2845,MCA_25340_4721819,00.html]

Prior to 1944, in British Columbia, the ''Public Schools Act (1872'') permitted the use of the Lord’s L-rd’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 L-rd’s Prayer. This amendment appeared as section 167 of the ''Public Schools Act'', and read as follows: [http://www.bccla.org/positions/freespeech/69religion.html]

<small>''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 L-rd’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''</small>

<small>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 L-rd’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.</small>

<small>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 L-rd’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.'' </small> </blockquote>

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.[http://www.religiousfreedom.ca]

<small>The Ontario Court of Appeal ruled that the use of the Lord’s L-rd’s Prayer in opening exercises in public schools offended the Charter s. 2(a). 1988. (1988), 65 O.R. (2d) 641, 29 O.A.C. 23 (C.A.).

The education regulations did not require the use of the LordL-rd'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 LordL-rd'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.</small></blockquote>

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. 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 L-rd’s Prayer and a Bible reading. The argument was similar to the Zylberberg case and the result was the same with the offending words in the act being struck out as being inconsistent with freedom of conscience and religion guarantees in the Canadian Charter of Rights and Freedoms.

<small>'''Russow v. British Columbia'''The B.C. Supreme Court follows Zylberberg case to strike down use of the Lord’s L-rd’s Prayer in schools. 1989. (1989), 35 B.C.L.R. (2d) 29 (S.C.)

*[http://www.religiousfreedom.ca "Charter section 2(a) cases"] Retrieved December 04, 2006