1n 1985 the Supreme Court of Canada, in the Town Cinema Theatres Ltd case, added that the "community standards" test is one of tolerance - not what Canadians think is right for themselves to see, but rather what they could not abide other Canadians seeing because it would be beyond contemporary standards of tolerance to allow them to see it. Material which exploits sex in a "degrading and dehumanizing manner" will fail the community standards test as it places women in positions of subordination, servile submission or humiliation which, if available, is likely to cause harm to society.
This definition unfortunately covers any form of kink including; BDSM, facials, rope play, watersports, worship, and humiliation. It also does not mention any form of queer sex, role-play, or consent. It places a focus on heterosexual sex and the treatment of females. The community standards test assumes that anything that is not pleasurable and acceptable to the dominant culture is obscene and harmful.