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This article compares how two closely related remedies, freedom of religion and belief discrimination, are applied by domestic courts in the United Kingdom and Germany. It concludes that the current practice of the courts in these two countries differs considerably and questions why that is so, given that the courts in both countries operate under essentially the same European legal framework determined by the ECHR and EU law. It is suggested that decision-making by domestic courts is still influenced by traditional domestic remedies and that domestic courts seem to find it difficult to adapt to new remedies. The article then gauges the potential for a common European approach, which, while theoretically possible, is unlikely to be triggered by either of the two European Courts. This is because cases dealing with religion often touch on core constitutional values, which both Courts usually respect.
