The claimant carried out work for the respondent between the months of January and June 2019.  He brought a claim for unfair dismissal which had previously been struck out for not having the requisite service requirements. He also brought a discrimination claim on the grounds of religion or belief under the Equality Act 2010 citing that his support for Rangers Football Club was such an intrinsic part of his life.  In evidence, it was found that he had been a supporter for around 42 years, he is a member of the club, goes to games regularly and that he has a ‘buzz’ on match days.  He outlined that there was a wider aspect to being a Rangers fan such as having loyalty to Northern Ireland and to the monarch. As a result, the claimant made the argument that supporting Rangers was as important to him as it was for others to go to Church.

The issue arose within the workplace when the claimant alleged that a manager, a Celtic fan, was not offering him work due to supporting Rangers. The issue for the Tribunal was to determine whether supporting Rangers could classify as a philosophical belief requiring protection within the ambit of the Equality Act 2010.

The Tribunal outlined that the test to be satisfied is that from Nicholson v Grainger.  That requires that the belief is genuinely held, not an opinion, a substantial aspect of human life, cogent, serious, important and worthy of respect in a democratic society.  The belief must not also conflict with the fundamental rights of others. In examining these details, the Tribunal found that the support of a football club was exactly that, support. It did not transcend from support and a lifestyle choice to one which could be regarded as a philosophical belief.  Considering the personal nature of the support it could not be said that the belief was important to the masses. As a result, the claim was dismissed.

Practical Lessons

The remit of philosophical belief is one that is not clear. There have been cases in the past relating to a myriad of issues including the likes of Veganism when it comes to what constitutes a philosophical belief. The Tribunal, in Scotland, has made it clear that supporting a football club, no matter how fervent that support may be, is such that it is a personal lifestyle choice. It must be stated that were this case in Northern Ireland then it may be such that the support for Rangers, considering the context, could have allowed for protection based upon the likes of political opinion. 
https://assets.publishing.service.gov.uk/media/631207718fa8f5578bc96ae2/Mr_E_McClung_v_Doosan_Babock___others_-_4110538.2019_-_Preliminary.pdf