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Former Supreme Court Justice Potter Stewart noted (in his dissent of Abington Township, 1963) ‘if religious exercises are held to be impermissible activity in schools, religion is placed at an artificial and state-created disadvantage. Permission for such exercises for those who want them is necessary if the schools are truly to be neutral in the matter of religion. And a refusal to permit them is seen not as the realization of state neutrality, but rather as the establishment of a religion of secularism.