Disciplinary action for quoting Bible passage was not discriminatory

The EAT hold that a warning given to a Christian for breaching prison policy by quoting a passage from the Bible that certain types of sexually-related behaviour is unrighteous did not constitute indirect discrimination.
religion

In Trayhorn v The Secretary of State for Justice, Trayhorn (T) is a Pentecostal Christian, and an ordained minister. A complaint was made that T had made comments during a service that marriage between homosexuals was wrong and needed stopping. T was instructed not to preach at services in the future, but while leading singing, he quoted a Bible passage about unrighteous sexually-related behaviour. A complaint was made that T’s “sermon had included God hating prostitutes and gays”. T was issued with a formal warning for breaching the prison’s disciplinary and equality policies. The EAT upheld an ET’s decision that T had not been indirectly discriminated against. There was no evidence that the prison’s policies disadvantaged Christians or Pentecostals as a group, nor did they put either T as an individual or individual Christians or Pentecostals at a disadvantage.


This update provides summary information and comment on the subject areas covered. Where employment tribunal and appellate court cases are reported, the information does not set out all of the facts, the legal arguments presented and the judgments made in every aspect of the case. Click on the links to access full details. If no link is provided, contact us for more information.  Employment law is subject to constant change either by statute or by interpretation by the courts. While every care has been taken in compiling this information, SM&B cannot be held responsible for any errors or omissions. Specialist legal advice must be taken on any legal issues that may arise before embarking upon any formal course of action.

Read more

Latest News

Read More

Revealed – unbelievable real workplace safety fails

3 July 2025

Newsletter

Receive the latest HR news and strategic content

Please note, as per the GDPR Legislation, we need to ensure you are ‘Opted In’ to receive updates from ‘theHRDIRECTOR’. We will NEVER sell, rent, share or give away your data to third parties. We only use it to send information about our products and updates within the HR space To see our Privacy Policy – click here

Latest HR Jobs

Queen Mary University of London – Health and Safety DirectorateSalary: £43,677 to £51,040 per annum This provides summary information and comment on the subject areas

University of Cambridge – Human Resources DivisionSalary: £33,482 to £39,355 per annum This provides summary information and comment on the subject areas covered. Where employment

University of Cambridge – Department of PathologySalary: £35,116 to £45,413 per annum This provides summary information and comment on the subject areas covered. Where employment

University of Exeter – PS ConnectSalary: The starting salary will be from £27,644 per annum pro rata on Grade D, depending on qualifications and experience.

Read the latest digital issue of theHRDIRECTOR for FREE

Read the latest digital issue of theHRDIRECTOR for FREE