In McAteer v. Canada (Attorney General) (Ont CA, 2014), in which a Charter challenge to the citizenship oath to the Queen was dismissed, the Court of Appeal clarified that such references in the oath (and apparently generally for legal matters) were not to the Queen of England as an individual person, but rather to "our form of government":
[6] For the reasons that follow I would dismiss the appeal and allow the cross-appeal. The appellants’ arguments are based on a literal “plain meaning” interpretation of the oath to the Queen in her personal capacity. Adopting the purposive approach to interpretation mandated by the Supreme Court of Canada, leads to the conclusion that their interpretation is incorrect because it is inconsistent with the history, purpose and intention behind the oath. The oath in the Act is remarkably similar to the oath required of members of Parliament and the Senate under The Constitution Act, 1867. In that oath, the reference to the Queen is symbolic of our form of government and the unwritten constitutional principle of democracy. The harmonization principle of interpretation leads to the conclusion that the oath in the Act should be given the same meaning.
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