Background
Colours parades have been a tradition in the Royal Bahamian Defence Force since its creation in 1980 and, at some of them, Christian prayers are said at one point in the parade [1]. From 1993 to 2006, pursuant to Coral Harbour Temporary Memorandum No 20/93, non-Christians could excuse themselves by falling out during the prayers and falling back in after them; but that was revoked by a further Temporary Memorandum No 67/06 in 2006 [2].
In Commodore Royal Bahamas Defence Force & Ors v Laramore (Bahamas) [2017] UKPC 13, former Petty Officer Gregory Laramore, a Muslim who objected to being obliged to attend Christian prayers on parade, challenged the constitutionality of the 2006 Memorandum [3]. Continue reading