In Mr C Wint v Walsall Metropolitan Borough Council [2025] UKET 1306321/2023, the claimant, a housing support officer at Walsall MBC, was a practising Christian born in the UK to Jamaican parents. He was off work sick from June 2022 to March 2023 with a bad back, then again from July 2023. He had not returned to work by the time of the hearing [31-33].

The case revolved around various comments made to him by colleagues but, in particular, a comment made by one Miss Shone, who allegedly said something to him like “I should have sent you a voodoo doll with pins in it” – but the precise words were disputed [43]. Mr Wint said that the comment was targeted at him as a Black Jamaican [45]. He made a claim for harassment, saying that Miss Shone’s alleged comment related to Voodoo and Voodooism, that as a Christian he was offended by it, and that the alleged comment was made because she was aware that Voodoo and witchcraft were in his view prevalent in black Jamaican and African culture [3].

The Tribunal rejected his claim [175], and the details of the case need not concern us further. What is very interesting from the point of view of “law and religion”, however, is that the Tribunal proceeded to consider whether Voodoo / Voodooism amounted to a religion and/or a religious or philosophical belief [119-147]. It concluded as follows:

• “There are temples, priests, a divinity and spirits, which provides a clear structure. There is a clear belief system in Bondye (in Haitian Vodou) and what that divinity represents, along with spirits, with morality being focussed in large part on the interrelationship with the Iwa and respect for the Bondye’s power” [127].
• “We conclude that this is a spiritual belief system which is held by a group of adherents (and on a worldwide basis, we note that there are a large number of people who follow Vodou / Voodoo, some openly and some less so). It explains mankind’s place in the universe and relationship with the infinite by reference to its divinity and spirits” [128].
• “From the material we have seen, we conclude that there are certain misconceptions within society about Voodoo / Vodou, and specifically about the Voodoo Doll” [131].
• “We conclude that Voodoo amounts to a religion within the meaning of the Equality Act 2010. We do not consider the Voodoo Doll to be an authentic element of that religion” [132].

Because Mr Wint was not a follower of Voodoo, the first of the Grainger criteria did not need to be applied [135-137]. As to the other tests, however:

• “it is clear to the Tribunal that a belief in Voodooism is a religious viewpoint on which many individuals agree, even though there are various permutations of the belief system itself. It is more than just an opinion or viewpoint” [141].
• Voodooism was “a belief as to a weighty and substantial aspect of human life and behaviour” [142]
• “Whilst there are differences in different countries, it is nevertheless coherent as a belief system with similarities across those practices, is intelligible and capable of being understood … Voodooism attains the required level of cogency, seriousness, cohesion and importance” [143].
• “We conclude that is it worthy of respect in a democratic society, not incompatible with human dignity and does not conflict with the fundamental rights of others” [146].
• “Therefore, in conclusion, Voodoo is a religion, and Voodooism is a religious belief. A belief in the power of the Voodoo Doll is not, however, a religious or philosophical belief under the Equality Act 2010” [147].