What Happened: Key Facts
- Parties & Legal Challenge
- The case, UKSC/2024/0095, was brought by a girl, referred to as JR87, and her father. (Supreme Court UK)
- They challenged how religious education (RE) and collective worship are taught in a controlled primary school in Belfast. (Supreme Court UK)
- Their argument: the RE curriculum breaches their rights under Article 2 of Protocol 1 (right to education) read with Article 9 (freedom of religion) of the European Convention on Human Rights (ECHR), as incorporated by the UK’s Human Rights Act. (Supreme Court UK)
- Supreme Court’s Decision
- On 19 November 2025, the UK Supreme Court unanimously ruled in their favour. (BBC Feeds)
- The Court found that the way RE and collective worship are provided in Northern Ireland does not meet human rights standards. (Sky News)
- Specifically, they said the curriculum is not “objective, critical, and pluralist” as required for it to respect diverse beliefs. (Sky News)
Why the Court Ruled It’s Unlawful: Reasoning
- The core syllabus for RE in Northern Ireland, drawn up by the Department of Education and the four main Christian churches (Catholic, Presbyterian, Methodist, Church of Ireland), encourages pupils to believe in Christian truths without sufficient critical or pluralistic framing. (Supreme Court UK)
- The Court was particularly concerned that the teaching “amounts to evangelism, proselytising, and indoctrination” because it encourages students to accept Christian beliefs as truth. (TheJournal.ie)
- While parents can legally withdraw their children from RE and collective worship, the Court found this isn’t an adequate safeguard:
- Withdrawal places an “undue burden” on parents. (Supreme Court UK)
- There’s a risk of stigma: a child might be isolated or singled out if withdrawn from compulsory Christian RE. (The Irish Times)
- The Court also criticized the lack of oversight: the Department of Education in Northern Ireland had failed to properly inspect or monitor how RE is taught to ensure human-rights compliance. (Supreme Court UK)
- Importantly, the Court clarified that this isn’t about ending all religious education:
- They didn’t say RE should be removed from schools. (Supreme Court UK)
- Rather, they said it must be reformed to reflect pluralism and critical thinking, not solely Christian doctrine. (TheJournal.ie)
Background / Legal History
- High Court (2022): The legal challenge initially succeeded: Mr Justice Colton ruled that the obligation to use a “Bible-based” curriculum violated the child’s rights under ECHR. (The Irish News)
- Court of Appeal: The Department of Education had appealed. The Court of Appeal accepted that the curriculum lacked pluralism, but said the right to withdraw made things lawful. (christian.org.uk)
- The Supreme Court overturned the Court of Appeal, reinstating the earlier High Court finding and going further on the duty to reform. (Supreme Court UK)
Reactions & Implications
- Human Rights / Secular Groups:
- Humanists UK (Northern Ireland) said the ruling is a “historic victory” for children’s rights and called for age-appropriate, non-confessional RE. (The Irish Times)
- They also argue this sets a precedent: more inclusive RE should be available across the UK. (The Irish Times)
- Northern Ireland’s Department of Education:
- The Department says it will carefully study the judgment and issues guidance to schools in light of the “complex” legal decision. (The Irish News)
- Legal / Educational Impact:
- The curriculum will likely need major reform: not just written differently, but revised by more than just church bodies. (Supreme Court UK)
- There may now be greater inspection and monitoring of how RE is delivered in schools, to ensure compliance with human-rights standards. (Supreme Court UK)
- The case could influence other parts of the UK: campaigners are calling on England, Scotland, and Wales to review their own policies on mandatory collective worship. (The Irish Times)
Why This Is a Big Deal
- Religious Freedom vs State Education: The ruling draws a strong line: states must not run RE that subtly (or not so subtly) pushes a religious doctrine as absolute truth.
- Pluralism and Diversity: It highlights the need for school curricula that present religion (and non-religion) in a way that respects all students’ beliefs.
- Child Protection: The Court is concerned about young children being exposed to beliefs that conflict with their or their family’s convictions, without adequate safeguards.
- Precedent for Reform: This could force a rethink not just in Northern Ireland but across the UK regarding how religious education is structured and taught.
- Here are case studies and expert/official comments centred on the UK Supreme Court ruling that Christian-focused Religious Education (RE) in Northern Ireland schools is unlawful. This breaks down how the ruling came about, who was involved, and the implications for schools, parents, and policymakers.
CASE STUDIES & COMMENTARY
CASE STUDY 1 — The Family Who Brought the Challenge (JR87)
Background
A father and his daughter (JR87) challenged her primary school’s RE and collective worship, arguing it was:
- Exclusively Christian,
- Confessional in tone, and
- Presented Christian beliefs as truth, rather than as one belief among many.
They argued this breached:
- Article 2 of Protocol 1 (Right to education)
- Article 9 (Freedom of thought, conscience, and religion)
of the ECHR.
Supreme Court Outcome
The Court agreed, saying the RE curriculum was not objective, critical, or pluralistic, and therefore unlawful.
Comment
Supreme Court judgment:
The curriculum encourages the acceptance of Christian beliefs as true and does not provide adequate balance or safeguards.
This case set the foundation for a complete rethink of RE across Northern Ireland.
CASE STUDY 2 — Failures in Safeguards & Inspection
Background
Schools argued that parents have a legal right to withdraw children from RE and collective worship.
What the Court Found
- Withdrawal is not enough to protect children’s rights.
- The process puts an “undue burden” on children and parents.
- Being withdrawn can create stigma or social isolation.
- The Department of Education had no effective inspection system to ensure RE was taught in a balanced way.
Comment
Justice Lady Rose:
A right of withdrawal cannot cure a system that is, in its structure, non-pluralistic.
This was a major criticism of the system beyond just the content of RE.
CASE STUDY 3 — How Controlled Schools Teach Religion
Background
Northern Ireland’s “controlled” schools — mostly attended by children from Protestant backgrounds — follow an RE curriculum written by:
- The Department of Education
- The four main Christian churches
Findings
The curriculum:
- Promotes Christian doctrine
- Encourages belief in Christian teachings
- Offers almost no teaching about non-Christian religions or humanism
Why It Matters
The Court found this creates religious favouritism in a state-funded system.
Comment
Human rights experts:
When churches write the curriculum, pluralism cannot be guaranteed.
This aspect is expected to change dramatically following the ruling.
CASE STUDY 4 — Attempted Reform & Why It Failed
Background
The Department of Education had promised reforms since 2022, after an earlier High Court ruling also found the curriculum unlawful.
But:
- No new syllabus was implemented
- No revised inspection framework was created
- Schools still taught the same materials in 2025
Impact
This failure was crucial to why the Supreme Court stepped in so strongly.
Comment
Supreme Court:
The Department’s inertia and lack of oversight are incompatible with its human-rights obligations.
This ruling forces immediate policy change that can no longer be delayed.
ADDITIONAL COMMENTS FROM KEY STAKEHOLDERS
1. Human Rights Organisations
Humanists UK:
A landmark decision that finally ends decades of confessional religious teaching in publicly funded schools.
They also call for similar reforms in England and Wales, where compulsory Christian worship still exists.
2. Churches
Representatives of the main Christian denominations expressed concern that:
- Religion may be “watered down”
- Schools may lose a sense of shared Christian heritage
However, some church leaders acknowledged that:
- Multifaith teaching is appropriate for today’s society
- The syllabus could be updated to reflect diversity
3. Teachers & School Leaders
Many principals welcomed clarity, saying:
- The old syllabus was outdated
- Teachers struggled to adapt lessons to a modern, diverse classroom
- A pluralistic curriculum makes teaching easier and more consistent
4. Academics & Legal Experts
Legal scholars say this ruling:
- Is one of the most important human rights judgments for UK education in decades
- May influence future cases on compulsory worship
- Could lead to the UK government reviewing RE nationwide
Why This Ruling Is Important
- Strengthens human rights protections for all pupils.
- Ends the state’s ability to promote one faith as objectively true in schools.
- Requires a new RE curriculum that includes:
- Christianity
- Other world religions
- Atheism & humanism
- Critical thinking about belief
- Forces a review of collective worship, which could be next.
- Sets a UK-wide precedent: England and Wales may face similar challenges.