In Copsey v WWB Devon Clays Ltd, the Court of Appeal has held that an employee's freedom to manifest his religious beliefs, under Article 9 of the European Convention on Human Rights, was not infringed by his (fair) dismissal for refusal to work on Sunday. The tribunal and the EAT were mistaken in finding that Article 9 was outside the concept of unfair dismissal under section 98 of ERA. However, on the facts of this case, the tribunal was correct to find that the employer had not failed to make reasonable accommodation for the employee's religious beliefs.