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For people with disabilities the duty to accommodate is a crucial tool for achieving substantive equality.

Commenting on that very point, Fiona Sampson writes: Historically, society has understood the experience of disability as rooted in the individual and has analyzed his/her difference in bio-medical terms.

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The Tribunal found in the alternative that, if a comparator group analysis is necessary, the appropriate comparator group is other students in the public school system who do not require additional supports or accommodations to access educational services.