Ordination training and employment status: Grabe

In Ms F Grabe v The United Reformed Church [2022] UKET 2204367/2012, Ms Grabe had been a candidate for the Ministry of Word and Sacrament in the URC between November 2008 and June 2012. The URC’s practice is that If a member of a local church wishes to discern a potential call to ministry, the local church refers the applicant to the regional Synod. If the Synod agrees, the candidate then attends an Assessment Conference made up of an Assessment Board and an interview with representatives of the Church’s Educational and Learning Committee, during which the candidate’s qualifications and general knowledge about the URC are ascertained and discussed. If the Assessment Board approves the candidate for ordination training the candidate and the Education and Learning Committee are so informed [25].

In 2008, Ms Grabe told her local church in Highgate that she wanted to explore the possibility of ordination training and the Church Council endorsed her as a potential candidate [54]. Following the Assessment Conference, the Education and Learning Board recommended her for two year’ training, including full-time study for the MA in Pastoral Theology at Westminster College alongside an internship year and other significant placements [60] and she was given a grant over the period from 2009 to 2012 totalling some £31,000 [63].

In 2012, the Church decided to terminate her candidacy for ordained ministry. That decision was communicated to her in a report of the Church’s Assessment Board in March 2012: she appealed, but her appeal was dismissed. She brought an employment tribunal claim of unfair dismissal, breach of contract, direct racial discrimination and victimisation and claimed for arrears of pay and holiday pay. The dispute has a long procedural history: there is a summary table with links here (complete with typos).

Following a preliminary hearing in 2017, Employment Judge Segal had determined that during her period of training as an ordinand Ms Grabe had in effect been employed under a contract of apprenticeship; further, that she had been “in employment” for the purposes of s.83(2) Equality Act 2010 [26].

Employment Judge A James did not agree. Ms Grabe’s claims for unfair dismissal, wrongful dismissal/breach of contract, direct discrimination because of disability and/or nationality/national origins, and/or philosophical belief, and/or sex, and/or sexual orientation, victimisation, harassment and whistle-blowing were dismissed.


Inter alia, Ms Grabe alleged philosophical belief discrimination relying on beliefs in “freedom to live in celibacy and freedom to live a Christian and Protestant Faith” [372]: EJ James agreed that both were protected philosophical beliefs [372], but could not understand  “how it could reasonably be argued by the claimant that the respondent Christian organisation would discriminate against her because she wanted to live ‘a Christian and Protestant Faith’” [374].

(See also our note on Professor Doreen McCalla v Lichfield Diocesan Board of Finance Inc & Anor [2022] UKET1303655/2021.)

Cite this article as: Frank Cranmer, "Ordination training and employment status: Grabe" in Law & Religion UK, 13 February 2023, https://lawandreligionuk.com/2023/02/13/ordination-training-and-employment-status-grabe/

4 thoughts on “Ordination training and employment status: Grabe

  1. Pingback: تمرین تمرین و وضعیت کار: Grabe - ganjine-roshan

  2. A minor correction, the United Reformed Church doesn’t have a body called a Church Council. I think that you might mean the Church Meeting of Highgate URC?

  3. Thanks: I took the terminology from the judgment and I should know better than to expect Employment Tribunals to be absolutely correct in their use of church terminology.

    (Incidentally, the relevant page on the Employment Tribunals website has several references to “The Untied Reformed Church”!) See https://www.gov.uk/employment-tribunal-decisions/ms-f-grabe-v-the-untied-reformed-church-2204367-2012#full-publication-update-history.

  4. The Claimant appears to have been treated with kid gloves and the indulgence shown her must have materially increased the costs incurred by the Defendant. The Tribunal system with its presumption against orders for adverse costs is not fit for purpose.

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