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Case Database 2009

This list includes judgments delivered in 2009.

United Kingdom

KELLY v UNISON (2009) Employment Tribunal Case Number 2203854/08 (22 December 2009): trade union members who were contending that they had been treated less favourably by Unison officials because of their Marxist / Trotskyite beliefs and membership of the Socialist Party were not protected under the meaning of the Employment Equality (Religion or Belief) Regulations 2003.   The expression ‘philosophical belief’ excludes political beliefs.

GNOSTIC CENTRE, RE [2009] Ch Commn (16 December): the Commission refused to register as a charity the Gnostic Centre (established ‘to promote and advance research on Gnosticism, both ancient and modern’) on the grounds that it encouraged a particular viewpoint based on the teachings and beliefs of Gnosticism and was not advancing education based on broad values that were uncontroversial and supported by objective and informed opinion, nor had not been possible to establish that a positive, beneficial, moral or ethical framework was being promoted because there was no evidence of shared morals or ethics among its followers.

E, R (ON THE APPLICATION OF) v JFS GOVERNING BODY & ANOR [2009] UKSC 15 (16 December): Lord Phillips PSC and Lords Mance, Kerr, Clarke and Lady Hale held that the admissions policy of JFS (formerly the Jewish Free School), which refused to admit a child who was not recognised as Jewish by the Office of the Chief Rabbi (OCR) because the OCR did not recognise the mother’s conversion, discriminated against him directly on grounds of ethnicity rather than of religion and was therefore unlawful under the Race Relations Act 1976; in addition, Lord Hope and Lord Walker held that though there had been no direct discrimination, there had been unjustifiable indirect discrimination: Lord Rodger and Lord Brown would have dismissed the appeal in its entirety,  considering this to be an exclusively religious requirement not dependent upon ethnic origin. See also E, R (ON THE APPLICATION OF) v JFS GOVERNING BODY & ANOR [2009] EWCA Civ 626 (25 June 2009)

LONDON BOROUGH OF ISLINGTON v LADELE [2009] EWCA Civ 1357 (15 December 2009): the Court of Appeal decided that the Employment Equality (Religion or Belief) Regulations 2003 did not give Ladele the right on religious grounds to refuse to have civil partnership duties assigned to her.  The Court agreed with the Employment Appeal Tribunal that Ms Ladele was neither directly nor indirectly discriminated against, nor harassed contrary to the 2003 Regulations, by being designated a civil partnership registrar, by being required to officiate at civil partnerships, or by any other aspect of her treatment by Islington London Borough. The Court concluded that except in the limited circumstances provided for in Regulation 14, the prohibition of discrimination in the 2007 Regulations took precedence over any right which a person would otherwise have by virtue of his or her religious belief to practise discrimination on the ground of sexual orientation. See also LONDON BOROUGH OF ISLINGTON v LADELE [2008] Employment Appeal Tribunal Case No. UKEAT/0453/08/RN (10 December 2008)

McFARLANE v RELATE AVON LTD [2009] UKEAT 0106_09_3011 (30 November 2009) : the Employment Appeal Tribunal upheld the Employment Tribunal decision that a Christian counsellor dismissed by Relate for failing to give an unequivocal commitment to counsel same-sex couples did not suffer direct or indirect discrimination under the Employment Equality (Religion or Belief) Regulations 2003 or unfair dismissal. The decision in LONDON BOROUGH OF ISLINGTON v LADELE [2008] Employment Appeal Tribunal Case No. UKEAT/0453/08/RN (10 December 2008) was followed.

SOCIETY FOR THE PROTECTION OF UNBORN CHILDREN, RE JUDICIAL REVIEW [2009] NIQB 92 (30 November 2009): the Guidance on termination of pregnancy issued by the Department of Health, Social Services and Public Safety in Northern Ireland was partly defective as to the law and should be withdrawn with a view to ‘being reconsidered by the Department taking account of the contents of this judgment’.

B (A CHILD), RE [2009] UKSC 5 (19 November 2009): though ‘in the ordinary way’ it is best for a child to be reared by his or her biological parents, in disputes about residence the child’s best interests are paramount.

GREATER MANCHESTER POLICE AUTHORITY V POWER [2009] EAT 0434/09/DA (12 November 2009): belief in spiritualism and the philosophical belief in life after death and psychic powers falls within the Employment Equality (Religion or Belief) Regulations 2003. 

RB (A CHILD), RE [2009] EWHC B26 (Fam) (10 November 2009): in the case of a baby suffering from an incurable congenital disease that made it impossible for him to breathe without artificial ventilation, the court agreed with the parents and the treating clinicians that it was in his best interests to allow him to die by administering a large dose of sedative and removing his ventilation tube.

GRAINGER PLC & ORS v NICHOLSON [2009] UKEAT 0219 090 311 (3 November 2009) : a belief in man-made climate change and the alleged resulting moral imperatives was capable, if genuinely held, of being a philosophical belief for the purposes of the Employment Equality (Religion or Belief) Regulations 2003.

X v MID SUSSEX CITIZENS ADVICE BUREAU & ANOR [2009] UKEAT 0220 08 3010 (30 October 2009): Ms X was a volunteer at the Mid Sussex Citizens Advice Bureau. In circumstances which did not arise for adjudication at the preliminary issue stage, she was asked by the CAB to cease to attend as a volunteer – whereupon she claimed for disability discrimination. The Employment Appeal Tribunal held that the first instance tribunal had not erred in finding that Ms X was not entitled to claim disability discrimination under the Disability Discrimination Act 1995 (DDA) as amended. The Government was not in breach of the Equal Treatment Directive (Council Directive 2000/78/EC) in that regard; nor did sections 4(2)(d) and 68 of the DDA fall to be read down or rewritten so as to extend protection to voluntary workers without a contract. The lower tribunal was also entitled to find that the CAB arrangements were not within section 4(1)(a) of the DDA (discrimination in the arrangements which the employer makes ‘for the purpose of determining to whom he should offer employment’), since there was no evidence that CAB volunteers were given any degree of preferential treatment in subsequent selection for paid employment.His Lordship refused to make a reference to the European Court of Justice in relation to the argument as to whether or not the Government was in breach of the Framework Directive.

EBR ATTRIDGE LAW LLP & ANOR v COLEMAN [2009] UKEAT 0071 09 3010 (30 October 2009): for an employer to treat an able-bodied employee caring for a disabled child less favourably than another employee in a comparable situation was associative discrimination, notwithstanding the specific references in the Disability Discrimination Act 1995 to ‘a disabled person’: see also COLEMAN v ATTRIDGE LAW & ANOR [2008] ECJ (GC) Case C 303/06 (17 July 2008).

UDDIN v CHOUDHURY & ORS [2009] EWCA Civ 1205 (21 October 2009): the Court was willing to accept evidence of a marriage under sharia law for the purposes of civil proceedings

DEPARTMENT OF HEALTH v INFORMATION COMMISSIONER [2009] Information Tribunal Appeal Number EA /2008/0074 (15 October 2009): in 2003 the Department of Health significantly reduced the detail of abortion statistics, prompting a freedom of information request; held, that the Department was required to disclose the information since it did not constitute personal data under the Data Protection Act 1998.

SECRETARY OF STATE FOR WORK AND PENSIONS v SISTER IS [2009] UKUT 200 (AAC) (8 October 2009): pursuant to Regulation 6(2)(b) and (3) of the State Pension Credit Regulations 2002, the two claimants were not entitled to a state pension credit because each was a member of a religious order and was fully maintained by that order.

AGE UK, R (ON THE APPLICATION OF) v ATTORNEY GENERAL [2009] EWHC 2336 (Admin) (25 September 2009): the Equal Treatment Directive has been correctly transposed into United Kingdom law and the compulsory retirement age of 65 was within the Government’s area of discretion – but the position might have been different had not the Government already announced a review of the Regulations and the Administrative Court could not see how the age-limit of 65 could remain after that review had taken place: see also R (AGE CONCERN ENGLAND) v SECRETARY OF STATE FOR BUSINESS, ENTERPRISE AND REGULATORY REFORM [2009] ECJ Case C-388/07 (5 March 2009)

MASIH v AWAZ FM [2009] Employment Tribunal Case Number 116403/2008 (26 August 2009): the tribunal made a reference to the EU Court of Justice for a preliminary ruling under Article 234 of the EC Treaty to determine whether a volunteer engaged to co-present a radio programme on a Community Radio is protected by the Employment Equality (Religion or Belief) Regulations 2003. See also X v MID SUSSEX CITIZENS ADVICE BUREAU & ANOR [2009] UKEAT 0220 08 3010 (30 October 2009)

R (ON THE APPLICATION Of HM CORONER FOR EAST LONDON) v SECRETARY OF STATE FOR JUSTICE [2009] EWHC (Admin) 1974 (31 July 2009): The coroner’s application for judicial review of the Secretary of State’s decision not to reissue a licence for the exhumation of the body of the deceased was refused. Since the body was buried in consecrated ground where a faculty would be required for exhumation, it was not for a court to express views on matters which it was for the Chancellor of the Diocese of London to decide.

SMITH & ANOR v MORRISON & ORS [2009] CSOH 113 (31 July 2009): the congregation of the Free Church of Scotland (Continuing) that broke away from the Free Church of Scotland after the schism in 2000 was not entitled to continue to occupy the Free Church of Scotland church and manse in Broadford, Isle of Skye, in contravention of the provisions of the trust deed.

PURDY, R (ON THE APPLICATION OF) v DIRECTOR OF PUBLIC PROSECUTIONS [2009] UKHL 45 (30 July 2009): the DPP is obliged to publish guidance on prosecution policy under  ss 2(1) & (4)  of the Suicide Act 1961 in respect of those assisting persons who commit suicide: the present situation was not ‘in accordance with the law’ for the purposes of Article 8(2) ECHR and did not give people sufficiently clear guidance to enable them, if need be with appropriate advice, to regulate their conduct in terms of the potential offence of assisting suicide: see also PURDY, R (ON THE APPLICATION OF) v DIRECTOR OF PUBLIC PROSECUTIONS & ORS [2009] EWCA Civ 92 (19 February 2009); (2009) 162 L&J 94-95.

EBURY (VALUATION OFFICER) v CHURCH COUNCIL OF THE CENTRAL METHODIST CHURCH [2009] 138 (LC) LT Case No RA/33/2007 (17 July 2009): two rooms within a church that were used as a coffee-shop and bookshop run by church volunteers were held to be ‘used in connection with’ a place of public worship and therefore attracted rating exemption under the Local Government Finance Act 1988 Sch 5 para 11(1).

JIVRAJ v HASHWANI [2009] EWHC (Comm) 1364 (26 June 2009): the Employment Equality (Religion or Belief) Regulations 2003 do not apply to the selection, engagement or appointment of arbitrators; and given that neither party to the particular arbitration agreement was a public authority, the provisions of the Human Rights Act 1998 could not be read into the Arbitration Act 1996. Moreover, though there was a ‘need to move with the times, it [was] inappropriate for the courts to trespass further than Parliamentary intention by way of filling what is suggested as a “lacuna” under the guise of public policy’.

E, R (ON THE APPLICATION OF) v JFS GOVERNING BODY & ANOR [2009] EWCA Civ 626 (25 June 2009): the refusal of JFS (formerly the Jewish Free School) to admit a child who was not recognised as Jewish by the Office of the Chief Rabbi (OCR) , on the grounds that that the OCR did not recognise the mother’s conversion, constituted a test of ethnicity rather than of religion and was therefore contrary to the Race Relations Act 1976: see also ADMISSION ARRANGEMENTS OF JFS, BRENT [2007] Determination by the Schools Adjudicator under the School Standards and Framework Act 1998 (Case Reference ada/001187) and E v GOVERNING BODY OF JFS & ANOR [2008] EWHC 1535/1536 (Admin) (3 July 2008)

HUDSON v LEIGH [2009] EWHC 1306 (Fam) (05 June 2009): a religious wedding-ceremony (in South Africa) that had been intentionally designed by the parties and the officiant not to constitute a civil marriage under South African law did not effect a valid marriage and it was not possible, therefore, subsequently to sue for divorce.

DEAN v BURNE & ORS [2009] EWHC 1250 (Ch) (05 June 2009): in a dispute between two rival groups of Russian Orthodox about ownership of church property following a change of allegiance of some parishioners from one jurisdiction to another, the court concluded that there had been continuity in obedience to the Patriarchate of Moscow after the departure of those who transferred their allegiance to the Ecumenical Patriarch and refused to order the division of the assets cy-près between the two factions: whether or not there was jurisdiction to direct such a scheme was in any case a matter for the Charity Commission.

CATHOLIC CARE (DIOCESE OF LEEDS) v CHARITY COMMISSION FOR ENGLAND AND WALES [2009] Charity Tribunal CA/2008/0003 (1 June 2009): a charity cannot seek to avoid the effect of the Equality Act (Sexual Orientation) Regulations 2007 by changing the objects clause in its Memorandum of Association. (Leave to appeal the determination (in part) was subsequently granted by the Tribunal.

McCONKEY & ANOR v THE SIMON COMMUNITY [2009] UKHL 24 (20 May 2009): under the Fair Employment and Treatment (Northern Ireland) Order 1998 it is not unlawful to discriminate against someone on the basis of concern about the actions that s/he might take in support of a religious belief or political opinion: ‘the Order is concerned with discrimination against someone on the basis of the religious belief or political opinion which he holds. It is not concerned with discrimination on the ground of actions that the person may take in support of that religious belief or political opinion’.

GHAI v NEWCASTLE CITY COUNCIL [2009] EWHC (Admin) 978 (8 May 2009): even in the case of a request from an observant Hindu, the prohibition on open-air funeral pyres under the Cremation Act 1902 etc (under which cremation may only take place in a crematorium the opening of which has been notified to the Secretary of State) does not contravene Articles 9 (religion) and 8 (private and family life) ECHR because the use of open-air was simply matter of tradition and ‘not a matter of dogma and belief’.

SANATAN DHARMA MAHA SABHA OF TRINIDAD AND TOBAGO INC & ORS v ATTORNEY GENERAL OF TRINIDAD AND TOBAGO [2009] UKPC 17 (28 April 2009): the creation of the Trinity Cross of the Order of the Trinity breached the constitutional rights of non-Christians to equality and to freedom of conscience and belief.

MAGA v ROMAN CATHOLIC ARCHDIOCESE OF BIRMINGHAM [2009] EWHC 780 (QB) (April 2009): an accusation in about 1976 of sexual abuse by a priest of the Archdiocese was not time-barred; however, the Archdiocese could not be held vicariously liable for the abuse since ‘the assaults … on the claimant were not so closely connected with [his] employment or quasi-employment by the Church that it would be fair and just to hold the Church liable’.

AGE CONCERN ENGLAND (INCORPORATED TRUSTEES OF THE NATIONAL COUNCIL FOR AGEING) v UNITED KINGDOM (Social policy) [2009] ECJ Case C-388/07 (5 March 2009): Council Directive 2000/78/EC on equal treatment has been correctly transposed into UK law in relation to the compulsory retirement age of 65.

CHONDOL v LIVERPOOL CITY COUNCIL [2009] UKEAT/0298/08 (11 February 2009): a social worker who had promoted his religious beliefs to service users by proselytising service users and, in one case, by providing a Bible, had not been unfairly dismissed, since his employer had objected to him inappropriately promoting his religion to service users and not his religion per se.


KOPPI v AUSTRIA [2009] ECtHR (No. 33001/03) (10 December 2009): refusal to exempt a preacher in a small Evangelical Church from compulsory civilian service did not violate the ECHR: even though exemption from military service was exclusively linked to membership of recognised religious societies and his Church was a registered religious community, religious groups could be treated differently so long as the overall policy was applied even-handedly.

MUÑOZ DÍAZ v SPAIN [2009] ECtHR (No.49151/07) (8 December 2009): where a marriage had been solemnised according to the traditional rites of the Roma community and the couple had been issued with a family record book by the Spanish authorities, the subsequent refusal to grant the widow a survivor’s pension on the ground that her marriage had no civil effects contravened Articles 12 ECHR (marriage) and 14 (discrimination) in conjunction with Article 1 of Protocol No. 1 (property); however, the fact that a Roma marriage had no civil effects as a marriage was not discriminatory under Article 14 (discrimination).

SEYIDZADE v AZERBAIJAN [2009] ECtHR (No. 37700/05) (3 December 2009): the applicant was refused registration as a candidate for the November 2005 parliamentary elections because he had continued to act as a ‘professional clergyman’ in spite of having given an undertaking to terminate any professional activity incompatible with the office of member of parliament and having resigned from all his positions involving professional religious activity: the First Section held that there had been a violation of Article 3 of Protocol 1 ECHR (free elections) because the relevant domestic law was not clear or precise and the restrictions in respect of Seyidzade had been arbitrary.

TAMARA SKUGAR & ORS v RUSSIA [2009] ECtHR 2159 (No. 40010/04) (3 December 2009): the refusal of the claimants’ requests to have their taxpayer’s identification numbers cancelled on the ground that the numbers ‘had been assigned to them through ignorance... because that number is a forerunner of the mark of the Antichrist as it is said in the Apocalypse, Revelation, 13:15-13:16’ (an issue that had been the subject of a clarificatory statement by the Orthodox Church to the effect that there were no theological grounds for objection to identification numbers) had not violated Article 9 ECHR (thought, conscience and religion) and the application was therefore inadmissible.

LAUTSI v ITALY[2009] ECtHR (No. 30814/06) (3 November 2009): the display of crucifixes in state schools was incompatible with the state’s duty of neutrality in the exercise of public services, particularly in the field of education, and violated Article 2 of Protocol No. 1 taken in conjunction with Article 9.

BAYATYAN v ARMENIA [2009] ECtHR (No. 23459/03) (27 October 2009): refusing to allow conscientious objectors to military service the option of alternative civilian service instead did not breach Article 9 ECHR (thought, conscience and religion), since military service was expressly excluded from the scope of the ‘forced or compulsory labour’ forbidden by Article 4 (slavery).

LOMBARDI VALLAURI v ITALY [2009] ECtHR (No. 39128/05) (20 October 2009) [French text only]: the refusal to consider for a permanent teaching appointment someone who had been teaching at a private Catholic university on temporary contracts for over twenty years, on the grounds that he held heterodox opinions, had violated his rights under Article 10 (expression) ECHR because the university had not specified how his alleged opinions had affected his teaching and how, therefore, they were likely to affect the university’s interests in providing education based on its religious beliefs: the procedural safeguards of the subsequent judicial review proceedings had also been inadequate and had violated Article 6 (fair hearing).

OZBEK & ORS v TURKEY ECtHR [2009] ECtHR (No. 35570/02) (11 October 2009) [French text only]: registration was refused for Kurtulus Kiliseleri Vakfi (Foundation of the Churches of Liberation) because it appeared that its fundamental purpose was to protect the interests of members of the Protestant community: the Foundation’s constitution had been misinterpreted because it was poorly-drafted and it was intended to provide support to the needy and victims of natural disasters, regardless of creed or religious affiliation: because the applicants were willing to amend the statutes of the Foundation so as to conform to their true intentions, the refusal to register the foundation violated Article 11 ECHR (association) as not necessary in a democratic society

APPEL-IRRGANG & ORS v GERMANY [2009] ECtHR (No. 45216/07) (6 October 2009) [French text only]: a neutral ethics course for schoolchildren, even though it was compulsory, did not violate Article 9 or Article 2 of Protocol No. 1 ECHR.

BOZCAADA KİMİSİS TEODOKU RUM ORTODOKS KİLİSESİ VAKFI v TURKEY (No 2) [2009] ECtHR (Nos. 37646/03, 37665/03, 37992/03, 37993/03 & 37996/03) (6 October 2009) [French text only]: a refusal by the authorities to enter on the Land Register a series of properties belonging to an Orthodox Church foundation violated Article 1 of Protocol No. 1 ECHR (peaceful enjoyment of possessions): (a revised and corrected version of a judgment issued on 3 March 2009).

KIMLYA & ORS v RUSSIA [2009] ECHR (76836/01 & 32782/03) (1 October 2009): a refusal to register two local Churches of Scientology that had not been in existence for the necessary  fifteen years required by the 1997 Federal Law on freedom of conscience and religious interfered with the applicants’ rights to freedom of religion and association, in violation of Article 9 ECHR (thought, conscience and belief) interpreted in the light of Article 11 (peaceful assembly and association).

TSARKNIAS v GREECE [2009] ECtHR (No. 24598/06) (24 September 2009) [French text only]: an application from a  Greek Orthodox priest who had joined the Orthodox Church of Macedonia and who had been convicted of using the basement of his house as a meeting-place for family members to hold Orthodox services in Macedonian, contrary to the law forbidding the erection or running of places of worship without the approval of ecclesiastical authority and the Ministry of National Education and Religious Affairs, was inadmissible on the grounds that he had not exhausted available domestic remedies.

MIROĻUBOVS & ORS v LATVIA [2009] ECtHR (798/05) (15 September 2009) [French text only]: the Government’s intervention in an internal dispute over leadership between two groups of (Orthodox) Old Believers had violated Article 9 ECHR (thought, conscience and belief) because the intervention breached the Government’s duty of neutrality.

AKTAS v FRANCE, BAYRAK v FRANCE, GAMALEDDYN v FRANCE, GHAZAL v FRANCE, JASVIR SINGH v FRANCE, RANJIT SINGH v FRANCE [2009] 17 July 2009 ECtHR 1142 (Nos. 43563/08, 14308/08, 18527/08, 29134/08, 25463/08, 27561/08) ( the link is to the ECtHR press release –  the individual decisions are available only in French): the Law of 2004 ‘on secularism’  which inserted a new Article L 141-5-1 into the Education Code prohibiting in State schools ‘the wearing of signs or dress by which pupils overtly manifest [manifestent ostensiblement] a religious affiliation’ and the subsequent Ministerial circular of 18 May 2004 banning headscarves, skull-caps or manifestly oversized crosses ‘which make the wearer’s religious affiliation immediately identifiable’ was justified and proportionate to the aim pursued – the complaints themselves were declared inadmissible.

MASAEV v MOLDOVA [2009] ECtHR (No. 6303/05) (12 May 2009): a fine on an unregistered Muslim group for practising their rituals was in breach of Article 9 ECHR; moreover, the requirement to register was an interference that did not arise from any pressing social need.

SFÂNTUL VASILE POLONĂ GREEK CATHOLIC PARISH v ROMANIA [2009] ECtHR (No. 65965/01) (7 April 2009) [French text only]: protracted delays in proceedings for the return of the applicant parish’s property, given to the Orthodox Church by the Romanian Government when the Greek Catholic Church was suppressed in 1948, violated its rights under Article 6 ECHR (fair trial) and Article13 (effective remedy): it was not necessary separately to examine the complaints under Article 9 (thought, conscience and religion) and Article 1 of Protocol No. 1 (peaceful enjoyment of possessions).

GÜTL v AUSTRIA [2009] ECtHR (No. 49686/99), LANG v AUSTRIA [2009] ECtHR (No. 28648/03), LÖFFELMANN v AUSTRIA [2009] ECtHR (No. 42967/98) (12 & 19 March 2009): discrimination against Jehovah’s Witnesses in relation to liability for compulsory civilian service (as an alternative to compulsory military service, which they were excused as conscientious objectors) was in breach of Article 14 ECHR (discrimination) taken together with Article 9.

VEREIN DER FREUNDE DER CHRISTENGEMEINSCHAFT & ORS v AUSTRIA [2009] ECtHR (No. 76581/01) (26 February 2009): the requirement of a ten-year waiting period in order to register as a religious community was unreasonable and in breach of Article 14 ECHR (discrimination) taken in conjunction with Article 9.

NOLAN & K v RUSSIA [2009] ECHR 262 (2512/04) (12 February 2009): refusing to allow a member of the Unification Church who had lived and worked in Russia legitimately to re-enter the country after going abroad had breached Article 9 ECHR; and because it had separated him from his baby son (of whom he was the sole carer and guardian) it also violated Article 8 (respect for private and family life).

HOLY SYNOD OF THE BULGARIAN ORTHODOX CHURCH (METROPOLITAN INOKENTIY) & ORS v BULGARIA [2009] ECtHR(Nos. 412/03 & 35677/04) (22 January 2009): the conduct of the Bulgarian Government with regard to a dispute between two competing factions of the Orthodox Church – the ‘alternative’ Holy Synod under Metropolitan Inokentiy and the ‘official’ Holy Synod under Patriarch Maxim – had been in breach of its duty of neutrality: by taking sides in a divisive controversy and evicting clergy and believers from their church property the authorities had interfered with their rights under Article 9 ECHR.

LARSN Case Database

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