Conisbee v Crossley Farms Ltd & Ors (England and Wales : Unfair Dismissal) [2019] UKET 3335357/2018 (6 September 2019)

Conisbee v Crossley Farms Ltd & Ors (England and Wales : Unfair Dismissal) [2019] UKET 3335357/2018 (6 September 2019)

Vegetarianism is not a protected philosophical belief under the Equality Act 2010 because it is an opinion or viewpoint, not a belief relating to a weighty and substantial aspect of human life and behaviour, lacks sufficient cogency and cohesion, and does not have similar status or cogency to religious beliefs. Claims against the third, fourth, and fifth respondents are dismissed for failure to comply with Early Conciliation requirements and, in the case of the third respondent, for being out of time and not just and equitable to extend.

Citation
[2019] UKET 3335357/2018
Parties
Claimant: Mr G Conisbee; First Respondent: Crossley Farms Limited; Second Respondent: Shane Foulger; Third Respondent: William Durrant; Fourth Respondent: Jamie Docker; Fifth Respondent: Justin (surname unknown)
Jurisdiction
United Kingdom
Judgment Date
06 September 2019
Procedural Posture
Employment Tribunal / Preliminary Hearing and Reserved Judgment
Outcome
Claims dismissed
Legal Topics
Philosophical Belief, Protected Characteristics, Discrimination, Jurisdiction, Time Limits, Early Conciliation
Employment Law Equality Law Philosophical Belief Protected Characteristics Discrimination Jurisdiction Time Limits Early Conciliation

Case Brief

Summary, issues, holding and outcome

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Parties

Mr G Conisbee

Claimant

Crossley Farms Limited

First Respondent

Shane Foulger

Second Respondent

William Durrant

Third Respondent

Jamie Docker

Fourth Respondent

Justin (surname unknown)

Fifth Respondent

Procedural Posture

Employment Tribunal / Preliminary Hearing and Reserved Judgment

Legal Issues

  1. 1 Is vegetarianism a protected philosophical belief under the Equality Act 2010?
  2. 2 Were claims against the third, fourth, and fifth respondents properly instituted under Early Conciliation rules?
  3. 3 Are any claims out of time and should time be extended?

Ratio Decidendi

Vegetarianism is not a protected philosophical belief under the Equality Act 2010 because it is an opinion or viewpoint, not a belief relating to a weighty and substantial aspect of human life and behaviour, lacks sufficient cogency and cohesion, and does not have similar status or cogency to religious beliefs. Claims against the third, fourth, and fifth respondents are dismissed for failure to comply with Early Conciliation requirements and, in the case of the third respondent, for being out of time and not just and equitable to extend.

Court Disposition

Claims dismissed

Orders

  • The claim that vegetarianism is a protected characteristic under the Equality Act 2010 is dismissed.
  • Claims against the third, fourth, and fifth respondents are dismissed for failure to comply with Early Conciliation procedures.