Is religious education in Northern Ireland unlawful?

On 19^th November 2025, the BBC reported that a court found that Religious Education in NI is unlawful. But is it true? Have schools and the Department of Education been breaking the law?

EUROPEAN PERSPECTIVES AUTOR 539/Paul_Coulter 27 DE NOVIEMBRE DE 2025 16:44 h

Photo via [link]Connected Christianity[/link].

On 19 November 2025, the BBC reported that a UK Supreme Court ruling found Religious Education in Northern Ireland unlawful. This followed a legal challenge by a primary school student, known as JR87, and her father against the Department of Education.

After winning initially in the High Court in 2022—prompting headlines about Christian-focused RE being 'unlawful' 1 —the Department appealed and won. JR87 and her father then brought the case to the Supreme Court, leading to the final decision on 19 November. 2

The case arose when JR87 started praying before meals at home and her parents questioned the interpretation of the school’s practice of teaching Christianity as “absolute truth,” arguing it violated their child’s religious freedom under Article 2 of Protocol 1 of the European Convention on Human Rights. 3

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[destacate]For our schools to fail to emphasise Christianity would amount to cutting off the branch they sit on, since our education system and the very idea of universal education for all arose from Christianity[/destacate]This article ensures the right to education and requires respect for parents’ religious and philosophical beliefs in teaching. JR87 and her father claimed that Northern Ireland’s primary schools were infringing these rights through their approach to religious education.

The school argued it was merely following the Department of Education’s core curriculum in how it teaches religious education and the legal requirement on schools to have daily collective worship.

In 2022, a High Court judge ruled that religious education was not "objective, critical, or pluralistic," and found the parental right to withdraw insufficient due to burden and potential stigma. 4

In 2024, the appeal court agreed the curriculum lacked objectivity but decided the withdrawal right was adequate to avoid breaching human rights; 5 however, the Supreme Court disagreed.

What does this mean for religious education in Northern Ireland’s primary schools?

It is, perhaps, easier to start by saying what it does not mean. The Supreme Court went to some lengths to emphasise that its ruling was not about:

Advancing secularisation – the Court was not suggesting that religious education should stop. Indeed, JR87 and G support religious education if it is not indoctrination.

Displacing Christianity as the main or primary faith children learn about in schools in Northern Ireland – the Court recognised Christianity’s unique importance in Northern Ireland.

Preventing evangelism or proselytising outside schools.

Interfering in the Department of Education’s role in setting the curriculum for religious education in Northern Ireland.

Preventing collective worship in schools in Northern Ireland being focused on the Christian religion.

In short, then, this judgement does not require all religions to be treated equally or an end to religious worship in schools.

The consistent message from each court ruling, however, is that the religious education curriculum needs overhauled to ensure delivery that is, “objective, critical, and pluralistic”.

[destacate]Where is the person who can be objective in speaking about religious matters?[/destacate]The Supreme Court judgement is clear in its conclusion that education that does not meet that definition equates to “indoctrination”.

This finding has been welcomed by Humanists NI, who described the judgement as, “a historic win for the rights of children in Northern Ireland,” and called on governments across the UK to repeal the requirement for mandatory collective worship in schools. 6

By contrast, Traditional Unionist Voice MP Jim Allister described the Court’s use of the term “indoctrination” as “inflammatory” and “an affront not only to teachers and parents but to the Christian foundations upon which our education system has long rested”. 7

Responses from Church leaders have been measured, with promises to review the judgement and openness to a change in the curriculum.8

Should Christians be concerned about this development?

At one level, this ruling seems inevitable given the changing religious landscape of Northern Ireland and especially the growing numbers of people who report having no religion – which increased from 10.1% in 2011 to 17.4% in 2021. 9

In an increasingly pluralistic society and globalised world, the idea of our children being educated about diverse religious beliefs and non-religious philosophies should not trouble us. Rather, it is good that they have some awareness of diverse beliefs.

At the same time, it seems appropriate that Christianity has special emphasis given its historic influence in Northern Ireland and the continued legacy of its values.

Indeed, for schools to fail to emphasise Christianity would amount to cutting off the branch they sit on, since our education system and the very idea of universal education for all arose from Christianity. 10

[destacate]I believe that critical thinking is good because I believe truth is objective and can be discovered. But I also believe that critical thinking can co-exist with faith[/destacate]The same could be said for the concept of human rights that was central to these court judgements. 11

To this, I might add that Christianity has nothing to fear from comparison with other belief systems. I am convinced that a Christian worldview is uniquely coherent, correspondent to reality, and compelling.

Coherent, meaning that it makes sense internally and has no logical contradictions. Correspondent, meaning that it makes sense of our experience of life.

Compelling, meaning that it commends itself to anyone who considers it fairly as both reasonable and true. I believe that no other system of belief can compare with Christianity on any of these measures.

We need not fear education about diverse beliefs if it is delivered fairly and clearly.

Are objectivity and critical thinking possible and desirable?

I have used the words fairly – meaning that the way the religion is described should not be a distortion – and clearly – meaning that it should be delivered at a level the person can understand.

I did not use the three words the Court used: objective, critical, and pluralistic.

These words were not chosen by the Supreme Court - they are well established in previous case law in the European Court of Human Rights. It is important to understand what they mean and how courts may mean something different than the average person would understand by them.

The word ‘pluralistic’ in this context is simply shorthand for the idea that education should not focus only on one religion.Many Christians are unlikely to find that unproblematic.

The word ‘critical’ is widely established in educational contexts. As a teacher in tertiary education, I frequently encourage ‘critical thinking’ in my students and grade their assignments on the basis of its presence of absence. It means that they should be able to evaluate different claims and make an informed, reasoned judgement about their relative weight.

That should be possible at tertiary level, but some may wonder what does “critical” mean in practice, especially when working with primary aged children who are not capable of “complicated reasoning” or able to “formulate detailed arguments”? 12

Primary School teachers who are convinced Christians – or adherents of any faith – may well wonder how they can show that their teaching of religion is critical.

The third word - ‘objective’ - is also are likely to be cause concern for many Christians. They might ask, where is the person who can be objective in speaking about religious matters? It may be helpful for the individual teacher to realise that the Supreme Court ruling is concerned primarily with the curriculum rather than with the actions of individual teachers.

Some may be reassured to know that they can speak with conviction themselves so long as the curriculum is balanced. But it remains to be seen how easy it is to make that distinction in practice and whether teachers will find themselves criticised or worse if they speak in non-objective ways about their own religion.

Religious people simply cannot speak about their faith in ways that are objective or critical, and non-religious people generally find it equally difficult to be objective about religion or their own philosophies.

Objectivity in religious matters is impossible partly because no one has grown up in a religious and philosophical vacuum and partly because no one has lived every religion from the inside – no one is qualified to make an objective judgement.

And how can a person who loves and worships a divine figure – in my case who loves God as Father and submits to Jesus as my Lord – speak critically of that figure?

[destacate]I do not expect everyone to agree with me, and I can encourage people to reach their own verdict, but I cannot speak about Jesus as if he was just one option among many[/destacate]I can certainly make it clear that I do not expect everyone to agree with me, and I can encourage people to reach their own verdict, but I cannot speak about Jesus as if he was just one option among many any more than the football fan can speak of his team as just one in a list or a wife about her husband as just another bloke.

In some matters objectivity and critical thinking are impossible. But there also comes a point where they are not desirable – when commitment and corresponding action are required – or practical – when a decision needs to be made.

Critical thinking is a useful tool, but it is not a workable end goal. It is only good insofar as it leads us to truth. Indeed, without the possibility of discovering truth it would consign us to an endless cynicism and paralysing indecision.

As a Christian I believe that critical thinking is good because I believe truth is objective and can be discovered. In this, my Christian worldview is coherent.

But I also believe that critical thinking can co-exist with faith. That is true not only for religious people. We all live by faith in some authority, whether a religious leader or text, a government, or ourselves.

Terms like ‘objective’ and ‘critical’ raise major challenges in everyday life. Who decides when any education meets this test? What other subjects might be taught in a way that fails it?

For example, is evolutionary theory taught in secondary schools – a stage when critical thinking is becoming possible – in a way that is objective and critical?

Is it fair to expect teachers to be able to meet this standard? Will t be applied consistently across the board or are religious matters to be subjected to a more stringent test than others?

These questions will need to be worked out carefully in any revised curriculum and guidelines for teachers.

The ruling on ‘indoctrination’

The Supreme Court’s comment on this point deserves quoting in full: 13

One of the issues on this appeal is whether teaching of religious education, which is not undertaken in an objective, critical, and pluralistic manner, amounts to pursuit of the aim of “indoctrination.”

It is important when addressing that issue to emphasise that Christians wish to encourage others to believe that “[t]here is but one living and true God” and to encourage others to practise the Christian faith as the only path to salvation: see the first Article of Religion in the Church of Ireland, see the first Article of the Church of Ireland 2009 Declaration on the 39 Articles of Religion, and see John 14:6, and Acts 4:12.

The word “indoctrination” ordinarily has negative connotations but in the context of the Christian faith it is a synonym for evangelism or proselytising.

It means winning others over so that they believe in and practice the Christian faith. In that sense indoctrination is an entirely proper Christian missionary process which seeks to secure salvation for others.

The word “indoctrination” is used in this judgment as a synonym for evangelism and proselytising devoid of any negative connotations.

It is important to realise that the Supreme Court had to consider whether RE amounted to indoctrination because that is part of the test as to whether the human rights of parents to raise their children within their own belief system are upheld.

The ruling found that the way RE is taught amounts to ‘indoctrination’ and therefore that the human rights of non-religious parents were being infringed.

In explaining this, the Court claims that ‘indoctrination’ is synonymous with ‘evangelism’. This is not the same as the standard dictionary definition of the word. The Cambridge Dictionary, for example, defines ‘indoctrination’ as “the process of repeating an idea or belief to someone until they accept it without criticism or question”. 14

The Court recognised that the word ‘indoctrination’ normally had negative connotations, but did not see this as reason to distinguish it from evangelism.

In attempting to distinguish the legal meaning of ‘indoctrination’ from its everyday negative sense, the Court uses language about Christian evangelism that goes beyond legal description and ventures into theological characterisation.

Many Christians will find this theologically inaccurate and pastorally unhelpful, because evangelism in Scripture is not coercive, repetitive instruction but open proclamation that respects conscience.

Christian theologians and pastors may agree with the Court’s interpretation of verses like John 14:6 and Acts 4:12 – Christians do believe that Jesus Christ is the only way to God. But they will likely disagree that this means evangelism is ‘indoctrination’. As the judgement says, Christians who evangelise “encourage others to believe” and they are about “winning others over”.

These phrases carry no sense of forcing someone to believe or giving people no option but to believe. Christians are likely to insist that evangelism is not indoctrination and may well worry about this ruling’s implications for evangelistic activities by churches and individual Christians.

Biblically, it is clear that the gospel cannot be imposed on people. Genuine faith in Christ must be a response from the heart. Christians do not seek to bypass or impose upon people’s consciences when they share the message about Jesus with them. Indeed, to do so is expressly forbidden in Scripture.

The apostle Paul outlines the correct approach in 2 Corinthians 4 verse 2:

we have renounced disgraceful, underhanded ways. We refuse to practise cunning or to tamper with God's word, but by the open statement of the truth we would commend ourselves to everyone's conscience in the sight of God.

This is a vitally important point because we realise that conversion is a work of God in a person’s life. No one can be educated or indoctrinated into God’s kingdom.

Of course, this is not always straightforward when it comes to children, who are often highly impressionable. I can understand the concerns of the parents in this case about their daughter praying before meals.

If my primary aged child came home from school and began to pray in the direction of Mecca or practising meditation, I would have concerns.

But the question remains as to whether the child in question was truly indoctrinated.

Whilst the specifics of that could not be tested by the Court and are legally irrelevant, they will interest many Christians.

A Christian might ask whether the child could have reached the conclusion that praying before meals is the right thing to do through her own judgement. They might might argue that she could have been responding to a work of God in her life and have come to the Jesus who invited little children to come to him? 15

The question of indoctrination works in all directions. It is possible that children could be indoctrinated out of belief in God by well-meaning parents or teachers. After all, research suggests that children naturally believe in the existence of a creator and do not acquire religious beliefs only through education or indoctrination. 16

In the final analysis, human rights law protects the right of parents to decide the religious and philosophical values their children are raised with. Most Christians will be glad of that right. It is only fair that they afford the same rights to parents of other faiths and none, and Christians should care about the impact on those parents as well as on themselves.

The Supreme Court determined that the right to withdraw children from RE is burdensome and doing so can stigmatise children. This is certainly an area for improvement. The challenge will be working that through without infringing the rights of Christian parents to have their children taught the Christian faith.

What about collective religious worship in schools?

The judgement also touches on the religious worship that is mandatory in schools in Northern Ireland (as in each constituent part of the UK) and usually takes place in assemblies.

It distinguishes between collective worship and religious education in terms of how they are delivered, but it lumps them together when concluding that the practice in Northern Ireland schools breaches human rights law.

It does not explicitly say that collective worship should be “objective, critical, and pluralistic”, but in using these words as the alternative to “indoctrination” and insisting that there should be no “indoctrination” in schools, it strongly implies that the same test should apply to collective worship.

And herein lies the greatest problem. If I cannot speak about God and Jesus dispassionately, then I certainly cannot speak to them without reverence and affection – or at least I should not! I presume the same is true for convinced followers of other religions.

[destacate]The Supreme Court judgement distinguishes between collective worship and religious education in terms of how they are delivered, but it lumps them together when concluding that the practice in NI schools breaches human rights law[/destacate]Controlled schools in Northern Ireland are state-funded and historically Protestant in ethos. They are required by law to include daily collective worship and this is typically Christian in nature but does not have to be.

The Supreme Court judgement does not require schools in Northern Ireland to include services from other religions in assemblies, but it seems likely that there will be increased pressure on schools to vary content of assemblies to reflect different religions.

Christian parents will then have to decide whether to withdraw their children from these assemblies.

At this juncture, Christians may arrive at varying perspectives. They might consider whether incorporating certain acts of worship from non-Christian traditions into primary schools is justified to preserve religious worship as an aspect of school life.

Questions also arise regarding the appropriate frequency of Christian-focused assemblies and whether there is a preference for eliminating collective religious worship in schools altogether, similar to practices in the United States.

Another relevant consideration is the impact of many years of Christian worship in educational settings; some might argue that it has contributed to widespread nominal Christianity, while others will contend it has provided children from non-churchgoing backgrounds with exposure to the gospel.

Commitments to make

Whatever our perspective on such questions, Christians can make some commitments as we reflect on this story.

Firstly, Christian parents should invest in teaching the faith to their children and leading them in family devotions and worship.

Secondly, churches should also invest in teaching children but should make sure that they are resourcing parents in their primary role.

[destacate]We should commit to speaking honestly and without manipulation, but not without conviction and passion[/destacate]Thirdly, the excellent work of parachurch organisations in evangelising children should continue with consent from their parents and they should continue to cooperate with schools where they can.

Fourthly, Christian teachers should be confident in the value of their vocation whether they are free to lead Christian worship in schools or not, they have a unique opportunity to show children and parents the good fruit of Christian faith.

Fifthly, no religious person should feel curtailed when speaking about their faith to be “objective and critical”. Such language may work for science and the arts but will not do for religious faith.

We should commit to speaking honestly and without manipulation, but not without conviction and passion.

Paul Coulter, author, executive director of the Centre for Christianity in Society in Northern Ireland. This article was first published on the author's blog, Connected Christianity.