Debating transgender issues can be really difficult. It is one of those areas where you cannot really articulate a position without using vocabulary that at least some people will find objectionable. Writing about it feels like treading through a minefield – one wrong step and you’ve caused offence.
But I’m going to try anyway because the case of Forstater v CGD Europe is a potentially important case about philosophical belief. It is also a case where much of the media debate is likely to miss the actual point of the decision.
The case has been brought by the Claimant Maya Forstater – a public policy researcher and writer who had a consultancy agreement with a not-for-profit think tank called the Centre for Global Development (CGD). She claims that following the end of her contract in December 2018 the CGD refused to engage her further because of comments she had made on Twitter and other forums expressing her beliefs about trans issues.
Now there is a temptation in a case like this to pick the side you are on before you look at the law or the actual evidence. You may take an instinctive stance based on your view of the nature of gender identity and how it relates to sex. There is a heated debate about ‘self-identification’ in particular and whether women only services or facilities are threatened by reforms that have been proposed to the Gender Recognition Act 2004.
This case is not about the rights and wrongs of that debate. Nor is it an unfair dismissal case. It seems clear that whatever the nature of the Claimant’s relationship with the CGD she did not have a contract of employment. Her complaint is not about dismissal. She is arguing that after December 2018 she was an applicant for employment within the meaning of the Equality Act 2010 – which has a wider definition of what counts as employment – and that the refusal to engage her was discriminatory.
This means that whatever else the Claimant’s case is about, it is not about whether the CGD acted fairly or reasonably. Those are not issues for the Tribunal to decide as they are irrelevant to her case. She is claiming direct discrimination and the question to be decided is simply whether or not she was refused employment because of a protected characteristic. If she was then she will win – and there will be no room for the CGD to argue that they acted fairly in refusing to engage her. If she was not refused employment because of a protected characteristic then she will lose (subject to an outstanding indirect sex discrimination claim) no matter how unfairly she may have been treated.
The first stage in winning her claim is to show the belief that she holds – and because of which she says she was refused employment – is protected by the Equality Act. The decision that has just been published comes from a preliminary hearing to decide that question.
The belief at issue is quite a complex one and I don’t want to over simplify or misrepresent it. Paragraph 41 of the Tribunal decision encapsulates, I think, what the Tribunal found the essence of her belief to be:
When questioned during live evidence the Claimant stated that biological males cannot be women. She consider that if a trans woman says she is a woman that is untrue, even if she has a Gender Recognition Certificate. On the totality of the Claimant’s evidence it was clear that she considers there are two sexes, male and female, there is no spectrum in sex and there are no circumstances whatsoever in which a person can change from one sex to another, or to being of neither sex. She would generally seek to be polite to trans persons and would usually seek to respect their choice of pronoun but would not feel bound to; mainly if a trans person who was not assigned female at birth was in a “woman’s space”, but also more generally. If a person has a Gender Recognition Certificate this would not alter the Claimant’s position. The Claimant made it clear that her view is that the words man and woman describe a person’s sex and are immutable. A person is either one or the other, there is nothing in between and it is impossible to change form one sex to the other.
So the question is whether this falls within the concept of ‘Religion or belief’ – one of the nine protected characteristics set out in S.4 of the Equality Act. Section 10 of the Act says ‘Belief means any religious or philosophical belief’ – but the Act doesn’t really give you anything else to go on.
There is no suggestion that the Claimant’s belief is a religious one, so the Tribunal has to decide whether it is a ‘philosophical belief’. The leading case on defining a philosophical belief is Grainger plc v Nicholson in which the EAT held that the employee’s belief in anthropogenic climate change was protected under the Equality Act. That case set out five criteria against which a belief should be judged in deciding whether it should count as ‘philosophical’:
(i) The belief must be genuinely held.
(ii) It must be a belief and not… an opinion or viewpoint based on the present state of information available.
(iii) It must be a belief as to a weighty and substantial aspect of human life and behaviour.
(iv) It must attain a certain level of cogency, seriousness, cohesion and importance.
(v) It must be worthy of respect in a democratic society, be not incompatible with human dignity and not conflict with the fundamental rights of others
The Tribunal applied these criteria and held that the Claimant’s belief met the first four of them but did not meet the last. Her belief was not worthy of respect in a democratic society because it was incompatible with human dignity and conflicted with the fundamental rights of others.
It must be quite a body blow to be told that fundamental belief that you hold is not worthy of respect in a democratic society. But this finding has not been plucked out of nowhere.
The Grainger criteria were based on the case law of the European Court of Human Rights. And importantly, the right of a trans person to have their acquired gender fully recognised in law was established by that Court in Goodwin v United Kingdom. It was as a result of that case that the UK Government introduced the Gender Recognition Act 2004 and the concept of a Gender Recognition Certificate – the effect of which is that:
…the person’s gender becomes for all purposes the acquired gender (so that, if the acquired gender is the male gender, the person’s sex becomes that of a man and, if it is the female gender, the person’s sex becomes that of a woman).
(S.9(1) GRA 2004)
Back to the Tribunal’s decision in Forstater. The key piece of reasoning is, I think in paragraph 84:
84. However, I consider that the Claimant’s view, in its absolutist nature, is incompatible with human dignity and fundamental rights of others. She goes so far as to deny the right of a person with a Gender Recognition Certificate to be the sex to which they have transitioned. I do not accept the Claimant’s contention that the Gender Recognition Act produces a mere legal fiction. It provides a right, based on the assessment of the various interrelated convention rights, for a person to transition, in certain circumstances, and thereafter to be treated for all purposes as the being of the sex to which they have transitioned. In Goodwin a fundamental aspect of the reasoning of the ECHR was that a person who has transitioned should not be forced to identify their gender assigned at birth. Such a person should be entitled to live as a person of the sex to which they have transitioned. That was recognised in the Gender Recognition Act which states that the change of sex applies for “all purposes”. Therefore, if a person has transitioned from male to female and has a Gender Recognition Certificate that person is legally a woman. That is not something that the Claimant is entitled to ignore.
The Tribunal’s finding is based squarely on the absolutist nature of the Claimant’s beliefs. I don’t think it is wholly outrageous to categorise them as being incompatible with the rights of those who hold a Gender Recognition Certificate as she denies the very thing that the Certificate is intended to achieve. The rights those holding a Certificate are specifically enshrined in law and are themselves derived from the European Convention on Human Rights.
As the Tribunal puts it:
The Claimant’s position is that even if a trans woman has a Gender Recognition Certificate, she cannot honestly describe herself as a woman. That belief is not worthy of respect in a democratic society. It is incompatible with the human rights of others that have been identified and defined by the ECHR and put into effect through the Gender Recognition Act.
I assume that this case will be appealed, but to be honest I think the Tribunal’s logic is pretty sound. I have seen a lot of commentary on Twitter to the effect that the decision is wrong and drawing all sorts of conclusions about its implications. But this is a view that seems to be based on strongly identifying with the Claimant’s beliefs rather than finding an actual flaw in the Tribunal’s reasoning.
Employment law is limited. It does not protect everyone and the protection it does give can be patchy and inconsistent. I am no expert on gender identity and how it relates to biological sex and I don’t seek to minimise the concerns and fears of individuals on either side of this debate. The Claimant in this case is perfectly free to hold the beliefs that she does and to argue for them in public and in private. But that does not mean that her beliefs must be protected under the Equality Act. If, as the Tribunal found, they are not then others are free to choose not to engage her services.
A Range of Reasonable Responses 
Excellent summary, Darren.
Darren! Thanks for the great overview. You are more than aware of my feelings in the matter and have given a really super overview. I’ve already shared widely.
The fundamental problem is with “It must be worthy of respect in a democratic society”. It’s fundamentally flawed. A belief of a provable fact is not open to whether or not is worthy of respect. A fact is a fact. “Worthy” is simply not applicable to objective facts.
I agree that the Grainger guidelines are problematic and this might be the case to challenge them.
But remember that while religious and philosophical beliefs are protected, mere opinions based on an assessment of evidence are not. If I was sacked for believing that The World is round I wouldn’t be able to claim discrimination. I would have to rely on a claim of unfair dismissal for which I would need to have two years’ continuous service.
The Tribunal misrepresents Forstater’s position though. She does not hold that a male in possession of a GRC cannot self-describe as a woman. Forstater holds that others cannot be forced to espouse the belief that this male is a woman if this conflicts with their own belief – that sex in humans is immutable, that a woman is an adult human female and that no male person can therefore ever be a woman, no matter what medical intervention or piece of paper they may avail themselves off.
I am also concerned that this judge has so thoroughly failed to understand the science that he managed to deny people with Differences in Sex Developments (whom he refers to as intersex throughout) their dignity in the scientifically rather illiterate sections of the judgement that are concerned with DSDs and all in the name of preserving the dignity of males who identify as trans. In all fairness though, this isn’t unique to the judge. Indeed, the Scottish Government earlier this year had to apologise to the DSD community for dragging them into the debate about transgender ideology and legislation.
Furthermore, I would like to add that a judge who neglects to consider that women as a sex class have rights both under international human rights legislation as well as currently under the Equality Act, rights which matter to and come into this debate in how we conduct it, will in my opinion find his judgement overturned on appeal. And rightly so. As females we currently have the right – in language and in law – to define ourselves in a category of our own, separately from males, no matter how they identify. This right has a bearing on this debate. This judgement suggests that we do not have this right and so suggests also that there is no basis for the protected characteristic of sex (other than belief maybe, but he has already ruled that this belief is not worthy of respect, so that leaves us with nothing at all). So according to him, our absolute right to define ourselves in our own category, to assemble and organise as a sex class, to fight for our rights outwith the presence of males, does not exist when it comes to males claiming womanhood.
Finally, I’m surprised you cannot see the chilling effect a ruling has that demands of us not only to deny reality, but that demands we do so to our own detriment. Or have you never considered how offensive it is to women to be told that we are a feeling in a man’s head? That what makes a woman are the magical words “I identify as”? A frock, a haircut, makeup and a propensity to cry at romantic movies? That our experiences of being female in a male-dominated world mean nothing? And that this ideology puts the blame for any suffering or injustice we endure for being female squarely at our own feet? For if a man can identify into womanhood and thus become a woman, all of us females, who have suffered horrific violence at the hands of males – whether as children or adults – and who’ve been discriminated against for being female, could have identified out of it if only we had been clever enough to think of escaping that way.
Charlie
Thanks for commenting in such detail.
It was not the purpose of this post to get into the debate about the nature of sex and gender. I am an employment lawyer who tries to explain how employment law works. I have no particular expertise in the area of sex and gender, but I do know a thing or two about discrimination law and the effect of a Tribunal decision.
If the judge has misrepresented the nature of the Claimant’s belief then I’m sure she will say so on appeal. The difficulty is that this will be a question of fact and appeals can only be made on a point of law. To succeed she will have to show that it was actually perverse of the Tribunal to characterise her belief as it did. Maybe she will succeed on that point, we will have to wait and see.
But of course if the judge has mischaracterised her belief then that will be good from your point of view. It is only the belief as set out by the Judge that has been held not to be covered by the Equality Act. There is plenty of room for other shades of belief to be covered.
The chilling effect of the judgement comes from the fact that those disappointed or angry at the outcome are overstating it’s effect. This is a first instance decision which creates no binding precedent. Other cases could easily be decided the other way, especially if the belief at issue is not the same as that identified by the Judge.
By the way, I don’t think the decision can fairly be seen as denying that sex exists or that women as a class are not protected. If it did say that it would obviously be wrong. Sex is definitely a protected characteristic under the Equality Act and no Tribunal has the power to change that.
I tried to make the point in my post that employment law is limited. It doesn’t protect everyone. Here the Claimant was arguing that her views fell under the category of ‘religion or belief’. Much of the commentary I have seen asserted that she is merely stating scientific fact. Ironically if that is true it undermines rather than helps her claim. Religion or belief as a protected characteristic does not cover evidence based opinions about scientific reality. If I was sacked for claiming that the World was round I would not be able to claim discrimination as a result.
This is a limited decision about the scope of a protected characteristic. It may turn out to be an important one, which asks the courts to look again at what counts as a philosophical belief. The Grainger criteria that I quote and which were binding on this Tribunal will not be binding on the higher courts and might be revisited. This process will take several years however, that’s just how it works.
It is perhaps worth considering that even if the Claimant wins on appeal, she may not win her case. There is a difference between holding a belief and acting in accordance with it. It is unlawful to treat someone less favourably because of their belief, but it might not be unlawful to sack someone who refuses to comply with a rule about behaviour that is applied to everyone. It could be argued that in this case – particularly towards the end of the judgment – the judge rather muddles this distinction. That may help the claimant in her initial appeal, but will still be problem if the case comes to a trial on its merits.
You and many others clearly feel strongly that the claimant has been badly treated here. That may well be so, but that does not mean that she must win her case. The Tribunal has to apply the law as it is and in my post I wanted to explain how that decision was reached and why. It was not a total rejection of all gender critical thought. Nor was it a green light to employers to sack employees who do not accept the prevailing view about the effect of a gender recognition certificate. It doesn’t help the wider debate to place to overstate what the judgment has done.
Thank you for your kind and clear response. I do understand that the actual self-id debate is outwith the scope of your article and that you are merely looking at it as an employment lawyer. I do also agree with you on several points you make about Forstater’s case, and am aware that this ruling cannot set legal precedent. The erroneous belief that it does, has – in my opinion – led to its significance being rather overstated on both sides of the debate.
However, I was mainly motivated to respond because of this point of yours:
“I don’t think it is wholly outrageous to categorise them as being incompatible with the rights of those who hold a Gender Recognition Certificate as she denies the very thing that the Certificate is intended to achieve.”
I realise now that I may have misunderstood what you meant. It now seems to me that your point can be read in two ways and while I took it to be in reference to Forstater’s actual, stated position, maybe you referred only to the situation immediately below, which is:
If Forstater had denied someone holding a GRC the right to be treated as a member of the opposite sex where no sex-based exemptions apply (for instance in terms of retirement age or how they are addressed at court or how an employer requires them to dress), then you would indeed be right – this would be incompatible with said person’s rights as protected under the GRA and not worthy of respect in a democratic country.
But that isn’t Forstater’s position at all. She does not deny a GRC holder any of the rights granted under the GRA. Her position is concerned with only two issues:
The first issue is that a GRC does not mean a person has literally changed sex. Sex in humans is immutable (and the existence of DSDs has no bearing on this at all). If one is born male, one cannot become female and vice versa. Hence we understand the GRC as a legal fiction conveying important legal protections on its holder. When it comes to the exemptions carved out in the GRA for female GRC-holders our contention that this is a legal fiction becomes a rather obvious fact. According to the judge’s interpretation of the GRC they are held to have changed sex for all purposes, but female GRC holders can legally neither inherit a title entailed to the first male heir nor can they enter the priesthood.
That’s precisely because the GRC does not actually turn them into the opposite sex and thus they remain excluded from these exclusively male privileges. This is a little known fact, of course, as it only concerns the rights of female GRC-holders (there are no such limitations placed on male GRC-holders in the GRA). In my view, the ruling making no mention of this obscure fact would have been fine, but the judge’s insistence that a GRC is not a legal fiction at all but official acknowledgment of a literal sex change is rather unfortunate in light of this.
With the Equality Act 2010 come the first limitations placed on male GRC-holders. Together with all other males, they can be excluded from any legal set asides for those of the female sex where this is a proportionate means and has a legitimate aim. I’ll not quote the exact set of circumstances, as they are readily available, but our current problem lies in the fact that those on the other side of this debate deny that these exemptions should and/or can be applied to any male who claims a trans identity, whether they hold a GRC or not.
That is Forstater’s first argument – those not actually of the female sex can be excluded from legal set asides for females under certain, limited circumstances. Even if the GRA states male GRC-holders are for all purposes female, they really are not female and therefore have no right to be included in these female-only legal set asides. As the EqA makes clear in its copious explanatory notes. And Forstater should be able to freely discuss this without being penalised by her de facto employer.
The second issue is about Forstater’s belief (or I would have called it a lack of belief in transgender ideology). Whether a GRC-holder carries a piece of paper or not, whether they have undergone medical treatment or even surgery to better emulate an opposite-sex body or not (as is increasingly the case), Forstater does not believe they have changed sex and she believes that she has the right to disagree with transgender ideology.
Of course this issue comes even more starkly into force when you look at the self-id debate Forstater engaged in, which is mostly not concerned with GRC-holders who have after all typically been diagnosed with gender dysphoria and often undergone medical treatment including genital surgery (only 900 of the UK’s 3000 male GRC-holders have not had surgery for instance). GRC-holders usually only come into it when the Equality Act exemptions are discussed. Self-id however means that we are confronted with a large number of males claiming a trans identity by merely stating “I identify as a woman”, ie self-declaring via words only. No meaningful transition is required at all. How and why such males have the right to expect people they do not actually know to curtail their freedom of expression when discussing the fact of these males’ sex eludes me.
It is rather unwise in my view that the judge decided to bring up Gregor Murray, because he seems to have failed to understand the background to the case. Murray was suspended and disciplined as a councillor for his unprofessional conduct in dealing with a local resident. Said resident privately requested that Dundee council correct a number of errors in its policies and on its website. Murray was forwarded this correspondence in his administrative role and promptly made his disgust with this request public and then proceeded to insult the resident publicly, too, in an astonishing display of misogyny.
Given the backstory, that the judge thinks such a person – who remains legally male after all – must be granted the privilege of having the pronouns of their choice respected by complete strangers is incomprehensible to me. And this is where Forstater argues that outside of a personal or working relationship (where she unequivocally stated she would respect anyone’s pronouns), she should have the right to correctly sex a person, especially one like Gregor Murray whose conduct as a person of the male sex is important within the context of the self-id debate.
Do you still hold – now that I have elaborated on Forstater’s actual position – that it is incompatible with the rights of GRC-holders for Forstater to express the belief that they have not actually changed sex given that she does so without denying them any of the specific protections a GRC entitles them to?
(The GRC does not after all include an obligation on the general public to refrain from disagreeing with the belief that GRC-holders have changed their actual sex. Neither does the EqA.)
Hi Charlie
To be perfectly honest – I just don’t know. I’m not a human rights lawyer. The furthest I would go is to say that I see the logic of the Tribunal’s position. I don’t say that I wholeheartedly agree with it. Again I think the problem is mixing up the abstract belief, with the likely behaviour of the claimant in a particular situation. This decision was – at the claimant’s insistence – only about the question of whether her actual belief, quite separate from any questions of how she would behave, qualified under the Equality Act. And of course it is the belief that the Tribunal found her to have that is the issue. The Tribunal may have got that wrong, but undoing it on appeal will be hard.
I can’t stress enough that Tribunal decisions are often a bit ropey, with poorly phrased sentences and errors of logic. The appeal courts are often quite tolerant of this, looking at whether basically the Tribunal was entitled to reach the decision it did. Mistakes may be forgiven if the court thinks they would not have altered the final result.
All of which is to say, we are perhaps subjecting this decision to a level of scrutiny that it should not be expected to bear. I know that sounds odd given the importance of the issue to so many people but it is the way the system operates. I’d at least wait until we have an EAT decision before getting worried about the implications of it and maybe even the Court of Appeal or Supreme Court.
I blame the internet. Until a few years ago hardly anybody would have read this decision and we would have had to wait until the EAT judgment was published and reported. Nowadays everybody is pulling it apart paragraph by paragraph and comparing it with the Claimant’s witness statement and original statement of claim. All of this will be rendered quite irrelevant once the EAT has made a ruling. I plan not to worry about it any more until at least then – sorry.
Darren
Please forgive the typos- it’s early!
Hi Darren,
A few years ago I did my PhD on the individual (as opposed to the institutional) right to freedom of religion. On the law there are a few issues:
1) Art 9 ECHR distinguishes belief from its manifestation. This is an important distinction, but the judge has run these two together when he states that a belief must be worthy of respect in a democratic society. As you correctly allude, it is tantamount to denying that the belief is protected under the ECHR.
Art. 9(1) of the ECHR defines what constitutes a belief and the manifestation of that belief. In the Forstater case the judge has held that her belief satisfies the first four requirements. He should have considered whether her manifestation of that belief, which was in fact proselytism, was sufficiently connected to those beliefs (actually this is a very interesting issue which could be developed at a theoretical level). I think it can be accepted that seeking to persuade others that the sex of a person should be defined by their chromosomes is sufficiently closely linked to the holding of the belief.
Thus under Art.9(1) Forstater has a belief and a manifestation which is, prima facie, protected under the ECHR.
Next step is consider under Art. 9(2) whether her manifestation shall be subject to any limitations. If there are to be limitations to the manifestation to her beliefs, then they have to be prescribed by law and are necessary in a democratic society. The phrase ‘necessary in an democratic society’ covers protecting the interests of public safety, for the protection of public order, health or morals, or for the protection of the rights and freedoms of others.
An early ECHR decision,Karaduman v Turkey (a Commission decision), made the same mistake as the judge in Forstater. The applicant in Karaduman, a Muslim, had successfully completed her studies at Ankara University and had requested a degree certificate. She supplied a photograph of herself wearing an Islamic headscarf. Her degree certificate was withheld because she did not supply a photograph of herself bareheaded as required by the Ankara University regulation. The Commission in Karaduman found there had been no interference with the applicant’s right to manifest her religious belief. In the words of the Commission: ‘‘accordingly finds no interference with the right guaranteed by Article 9 para. 1 of the Convention’’.9 So no issue arose to be determined under Art.9(2). As I have explained above this is not the way to evaluate Art. 9 ECHR. However, the Chamber and Grand Chamber in Leyla Sahin has reinterpreted Karaduman to be a case where there has been an interference but one that was justified under Art.9(2)! The ECourtHR does now follow the analysis of Art. 9 rights in the way I have described above.
The judge in Forstater should have explicitly considered what interests are being protected in the interests of a democratic society. The consultation on the reform of the GRA 2004 is bound to result in a diversity of views. The judge should have weighed up the current legal position under the GRA 2004 and restricting such a manifestation against the rights of others to have their right to freedom of expression protected and protecting Forstater’s right to have her Art. 9 ECHR right protected.
HG
TBH I simply don’t understand this reliance on a GRC giving a person the status of their assigned sex “for all purposes” when the GRA *itself* contains exemptions highlighting all the ways that a person remains their birth sex. If a GRC makes you male/female for all purposes except x, y and z, then a distinction remains.
Quite aside from the conflation of biological and legal definitions of sex, surely it falls over on that count.
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I have done some ET representation, and am trans, so was glad of the decision, and don’t see any grounds for appeal.
Of course human beings have a biological sex; but we also have a gender assigned from the moment of birth. People talk to you differently depending on what sex they think you are. Just because gender is cultural, does not mean it is not real, and have real effects on people.
Forstater’s belief, she claimed, entitled her to refer to a trans woman as “he”, a trans man as “she” and a non-binary person by the pronoun she thought appropriate, rather than “they”. As the employment judge stated, we would tend to feel insulted by that. A belief which entitles the claimant to insult people is not a belief entitled to protection. And an employer should be entitled to dismiss her for sharing her blog post round colleagues, if the employer found the views therein offensive, or thought there was a risk she might insult clients or business partners.
I find her blog post offensive. Trans people exist. We have been transitioning for millennia, in all sorts of cultures. Just because “sex is real” does not mean we vanish in a puff of logic. And, we are mostly harmless: just because some of us are criminal does not mean we should all be excluded, any more than Scots should be deported en masse because some Scots are in English prisons.
A gender recognition certificate entitles us to very little. Before state retirement pension age was equalised, it affected that, and before equal marriage it affected whether we could enter a marriage or civil partnership, but now it is mainly symbolic that the state sees me as a woman. But before the GRA I had a passport marking my sex as “F” and a driving licence which, if you knew how, you would see indicated I am female. Before the Equality Act I went into women’s loos, with a card from my psychiatrist in my handbag confirming my diagnosis and saying I should be allowed to. The GRA does not affect Equality Act rights, either the right to enter women’s spaces, which applies from the moment I “propose to undergo… a process (or part of a process) for the purpose of reassigning the person’s sex by changing physiological or other attributes of sex”. With my GRC, I can still be excluded from women’s spaces if it is a “proportionate means of achieving a legitimate aim”.
Next month comes the hearing on whether she was entitled to claim unfair dismissal or not, and there are still sex discrimination claims to be dealt with. FWIW, I think her indirect discrimination claim fails: I don’t think women are more likely to believe trans women are men than men are, or more or less willing to [treat us with courtesy/flatter our delusions/delete as applicable].
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