In Kuteh v Dartford and Gravesham NHS Trust the Court of Appeal has agreed that the human right to freedom of religion did not make it unfair for an employer to dismiss a nurse for improperly proselytising to patients and failing to follow a lawful management instruction to stop initiating conversations with patients about religion. The ruling mirrors previous case law establishing that inappropriate promotion of religious beliefs is not unlawful religious discrimination. There is a distinction between manifestation of religious belief and the inappropriate promotion of that belief.