School Chaplain’s claims for discrimination on the grounds of religion and religious belief fail

In the recent case of Randall v Trent College Ltd and others a school chaplain presented various discrimination claims based on his religion and religious beliefs. As a Christian Mr Randall’s protected characteristic was unchallenged.

Trent College Ltd is an Anglican foundation, co-educational, independent day and boarding school which objected to and defended the numerous claims of harassment on the grounds of his religious or philosophical belief, direct religious discrimination, victimisation and unfair dismissal.

Issues arose between the parties after Mr Randall delivered two sermons about ‘competing ideologies’.

First sermon

The sermons were delivered to pupils aged 11 to 18 years old with the first one focusing on gender equality, gay marriage and LGBT+ rights. The first sermon strongly implied that it was sinful to alter the body given by God, that marriage can only be between a man and a woman and that a family works best when a woman, given her tone of voice, looks after the children.

The school received numerous complaints from pupils after this sermon.

Second sermon

His second sermon covered the ‘LG’ in the LGBT+ and implied that homosexuality was sinful. Further, that homosexuals should remain celibate as the majority of Christians held the view that homosexuality is a sin. Mr Randall said in his sermon:

"So the key question for Christians is whether same sex marriage is possible within a Christian worldview. Clearly it is a legal reality now in this country. But it’s worth putting that into some kind of perspective, I think. Because if you think that same sex marriage is obviously right, you’d be in a minority – at least if you consider everyone in the world, and all the people throughout history. Same sex marriage is new and that’s worth bearing in mind…. So that’s the majority Christian view, as it is around the world at the moment……."

Summary dismissal

This upset staff, pupils and parents, some of whom complained or led petitions of equality and ultimately, further to a disciplinary investigation, led to Mr Randall’s summary dismissal on 30 August 2019. Indeed, the number of complaints received were said to be ‘unprecedented’ and the overwhelming theme was that the sermon appeared to suggest it was wrong to be LGBT+ and okay to discriminate.

Appeal and reinstatement

Mr Randall appealed the decision to dismiss him and was later reinstated on appeal but he was subsequently dismissed by reason of redundancy. The school also reported Mr Randall to the Local Authority Designated Officer (LADO) and ‘Prevent’ (a programme for preventing radicalisation of children) given the views he shared. These two reportings were given as examples of the harassment he claims he was subjected to as part of his claim. Neither the LADO nor Prevent took further action.

Tribunal decision

Mr Randall had been warned about earlier sermons he had given on marriage, sexual orientation and gender identity. The school asked Mr Randall to ensure sensitive topics were dealt with in the classroom setting, where views and ideas could be discussed and challenged. Addressing these views as sermons in the Chapel, did not allow for such discussions to take place and risked psychological harm to the pupils, who may be coming to terms with their own sexuality.

The tribunal found that the school’s advice had been disregarded and that the school had therefore been justified in objecting to Mr Randall’s actions. Crucially, the tribunal found that he had ‘used his position of authority to risk harm for his own gratification’ and that he embarked on his sermons in the full knowledge that it had the potential to harm vulnerable pupils.

None of his claims succeeded.

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