Mandla v Dowell-Lee

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Mandla v Dowell-Lee
Two Sikhs.jpg
A sikh wearing patka (right)
Court House of Lords
Decided 24 March 1983
Citation(s) [1983] UKHL 7, [1983] 2 AC 548
Case history
Prior action(s) [1983] QB 1
Court membership
Judge(s) sitting Lord Fraser of Tullybelton, Lord Edmund-Davies, Lord Roskill, Lord Brandon of Oakbrook and Lord Templeman
Race discrimination, Sikh, protected characteristic, ethnicity

Mandla v Dowell-Lee [1983] UKHL 7 is a United Kingdom law case on racial discrimination. It held that Sikhs are to be considered an ethnic group for the purposes of the Race Relations Act 1976.


A Sikh boy was refused entry to Park Grove School, Birmingham by the headmaster, because his father refused to make him stop wearing a dastar and cut his hair. The boy went to another school, but the father lodged a complaint with the Commission for Racial Equality (CRE), which brought the case. Derry Irvine, a future Lord Chancellor, appeared for the CRE.


Court of Appeal[edit]

The CRE lost in the Court of Appeal.[1] Lord Denning, M. R. held the following:

He held that Sikhs were not a racial or ethnic group.

House of Lords[edit]

The CRE won the Appeal to the House of Lords,[2] where Lord Fraser of Tullybelton held the following.

He went on to approve the test set out by Richardson, J. in the County Court.

They held that Sikhs were a racial or ethnic group.


The outcome of this case has been that it has led to a legal definition of the term ethno-religious.[3][4]

See also[edit]


External links[edit]