Conisbee v Crossley Farms Ltd and others ET/3335357/2018 has found that vegetarianism is not a “belief” for purposes of Equality Act 2010

Mr Conisbee was employed for approximately 5 months before resigning. He alleged discrimination on the ground of religion or belief contrary to the Equality Act 2010, his belief being vegetarianism. At a preliminary hearing, an employment tribunal held that this belief did not qualify for legal protection.

The test for the judge to consider was one of whether vegetarianism is a philosophical belief.

Under the Equality Act it is unlawful to discriminate in the workplace because of religion, religious belief, philosophical belief or lack of religion or belief. 

The Act does not define precisely what a philosophical belief is and which specific beliefs are protected, through the development of case law there are certain criteria, set out below, which must be met in order for any belief to fall within its ambit:

•           A belief must be genuinely held, although it doesn’t need to be shared by others;

•           It must be a belief, not just an opinion or viewpoint based on the present state of information available;

•           It must relate to a weighty and substantial aspect of human life and behaviour;

•           It must attain a certain level of cogency, seriousness, cohesion and importance;

•           It must be worthy of respect in a democratic society, not be incompatible with human dignity and not conflict with the fundamental rights of others;

•           It must have a similar status or cogency to a religious belief, but it doesn’t need to allude to a fully-fledged system of thought.

In this case it was held that:

•           vegetarianism is not about human life and behaviour; it is a life style choice and in Mr Connisbee's view believing that the world would be a better place if animals were not killed for food;

•           the judge claimed that vegetarianism lacked the necessary level of cogency, seriousness, cohesion and importance.  Namely, that the reason for being a vegetarian differs greatly, some adopt the practice for lifestyle, health, diet, concern about the way animals are reared for food and personal taste. On this point, the tribunal contrasted veganism, stating, obiter, that the reasons for being a vegan appear to be largely the same and that there was therefore a clear cogency and cohesion in vegan belief.