Claimant v Institute and Faculty of Actuaries

Outcome

Facts

The claimant, Patrick Lee, brought discrimination claims against the Institute and Faculty of Actuaries based on his belief that unreformed Islam is problematic and deserving of criticism due to its incompatibility with Western liberal values including separation of religion and state, human rights, and gender equality. The respondent investigated 83 tweets the claimant made between March and August 2020, finding 42 offensive and 29 designed to demean Muslims. The key dispute was whether the claimant's pleaded belief was genuinely held or was an artificial construction masking more extreme views.

Decision

The tribunal found that the claimant genuinely held the pleaded belief at all material times, which is therefore a protected philosophical belief under s.10(2) Equality Act 2010. The judge accepted the claimant was critical of specific Islamic doctrines and practices rather than individual Muslims, and that his tweets were manifestations inveighing against these doctrines. Whether the tweets were appropriate manifestations or separable from the belief would be determined at the final hearing in February 2026.

Practical note

Legal authorities cited