Key facts of the case - A Rastafarian who wore his hair in dreadlocks was refused employment as a van driver by a government agency when he indicated that he was unwilling to cut his hair. He complained of unlawful direct and indirect discrimination on the ground of his race, contrary to the provisions of section 1(1)(a) and (b) of the Race Relations Act 1976. An Industrial Tribunal upheld his complaint, considering that Rastafarians were an ethnic group as stated in the leading House of Lords case of Mandla v. Dowell Lee [1983] 1 All ER 1062; [1983] IRLR 209.

Main reasoning of the court - The Employment Appeal Tribunal, by a majority, allowed an appeal by the government agency and the applicant’s appeal to the Court of Appeal was dismissed. The Court of Appeal considered that there was nothing to distinguish Rastafarians from the rest of the Afro-Caribbean community so as to render them as a separate group defined by reference to their ethnic origins. Further, a 60-year history was not sufficient to amount to a ‘long shared history’, one of the essential criteria set out by the House of Lords in the case of Mandla v. Dowell Lee.