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Mandla v Dowell-Lee

Mandla v Dowell-Lee [1982] 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.

Mandla v Dowell-Lee
Two Sikhs.jpg
A sikh wearing patka (right)
CourtHouse of Lords
Decided24 March 1983
Citation(s)[1982] UKHL 7, [1983] 2 AC 548
Case history
Prior action(s)[1983] QB 1
Court membership
Judge(s) sittingLord Fraser of Tullybelton, Lord Edmund-Davies, Lord Roskill, Lord Brandon of Oakbrook and Lord Templeman
Race discrimination, Sikh, protected characteristic, ethnicity


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 AppealEdit

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 LordsEdit

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 alsoEdit


  1. ^ [1983] QB 1
  2. ^
  3. ^ "Anti-Discrimination (Amendment) Bill - 11/05/1994 - 2R COMM - NSW Parliament". 1994-05-11. Retrieved 2015-04-27.
  4. ^ "Archived copy". Archived from the original on 2010-01-16. Retrieved 2010-02-10.CS1 maint: archived copy as title (link)

External linksEdit