Patrick Lee v Institute and Faculty of Actuaries — 2025

At a preliminary hearing on 29-30 July 2025, Patrick Lee pursued only the pleaded belief that Islam, particularly in a traditional form, is problematic and deserving of criticism because it does not separate religion and politics and does not respect fundamental human rights, including freedom of conscience and speech, rejection of violence in the name of religion, and equal treatment of women and girls. He had withdrawn three of the four beliefs or lack of beliefs originally pleaded. The tribunal refused his application to amend to an alternative formulation, finding that he had not shown why the amendment was necessary and that allowing it would prejudice the respondent and delay determination of the issue.

The only live dispute was whether the pleaded belief was genuinely held, for the purposes of the first Grainger criterion. The tribunal found the claimant to be a reliable witness and accepted his evidence that he was critical of doctrines and practices rather than of individual Muslims or Islam as a whole. It accepted that he believed the doctrines described in his evidence were authoritative, were sanctioned by Islamic leaders, and were harmful because they could justify violence and unequal treatment of women and girls.

The tribunal held that the wording in the pleaded belief about a traditional form of Islam was simply a convoluted way of referring to unreformed Islam, and did not require the claimant to believe that reform was possible. It also held that the respondent's reliance on the claimant's tweets did not make the pleaded belief and those tweets mutually exclusive, and that issues about manifestation of belief were matters for the final hearing. The tribunal therefore found that the claimant genuinely held the pleaded belief at all material times and that it was a protected belief under section 10(2) of the Equality Act 2010. No remedy was awarded because the judgment decided only this preliminary issue.