Prepare a short casenote, summarising the key facts, issues and the ratio decidendi of the case at both appellate levels, alon

Issues : - Whether there was discrimination under section 1(1)(b) of the Race Relations Act 1976 by determination of a "racial group" under section 3(1).

Ratio Decidendi : - Sikhs are not considered as a "racial group" under section 3(1) of the Act, as they are only distinguishable by their religion and culture and not by any racial characteristics ("ethnic origins") in order to be liable to be discriminated against under section 1 (1)(b) of the Race Relations Act 1976.

Mandla v Dowell Lee [1983] 2 WLR 620 - House of Lords

Facts : - Sikh father applied for his son to apply to attend a multiracial private school

- Application refused by headmaster

- Reasoning was turban worn by son not part of the school uniform code

- Father brought action against the school for racial discrimination under Race Relations Act 1976.

Issues : - Whether Sikhs were a "racial group" defined by "ethnic origins" under section 3(1) of the Race Relations Act 1976 to qualify as being discriminated against.

- Whether the respondent has been indirectly discriminated against under section 1(1)(b) by defining the meanings of "can comply" under section 1(1)(b)(i) and "justifiable" under section 1(1)(b)(ii) of the Act.

Ratio Decidendi: - The Sikhs would qualify as a group defined by ethnic origins for the purposes of the Act given the wider meaning of "ethnic origins" in a broad cultural/historical sense.

- There has been indirect discrimination under section 1(1)(b) of the

Act in defining paragraphs (i) and (ii) of the relevant section:

- The word "can" has been intended by Parliament to mean "can in practice" or "can consistently with the customs and cultural conditions of the racial group", therefore, they "can comply" i.e. have the option of complying, with any condition that affects their "distinctive customs and cultural rules" to protect them from discrimination.

The "No Turban Rule" is not a necessary condition or requirement of the school and is therefore "unjustifiable" according to paragraph (ii) of section 1(1)(b) of the Race Relations Act 1976.