In Shergill & Others v. Khaira & Others [2014] UKSC 33, the UK courts considered whether a Sikh holy saint had the power to dismiss trustees who questioned his “succession” to the religious institution of the Nirmal Kutia Johal. The Supreme Court, reversing the decision of the Court of Appeal that religious questions were “nonjusticiable,” reinstated the judgment at first instance of the High Court to the contrary. The decision of the Supreme Court is important because whenever questions of the identification and legitimacy of successors to a religious institution have arisen, their “justiciability” before a secular court has invariably been a bone of contention on grounds that it threatens the autonomy of religious institutions. In Shergill the Supreme Court got around these concerns by drawing a normative distinction between the public law of the land (which the courts are required to determine), and the internal private law of a religious institution on matters of succession, ordination, and removal (which are not in themselves for the courts to decide). But Shergill also went further than previous case law in two respects. First, the fundamental tenets of a belief system are capable of an objective assessment by a secular court provided that there is public law element to a dispute, in which case the court can then decide on the fitness of the successor for office. This means there is no general presumption that a secular court is barred from considering religious questions per se. Second, these principles apply just as much to the judicial consideration of non-Christian faiths as they to the Christian religion, and this is so notwithstanding the court's unfamiliarity with other faiths.

This article is based upon qualitative research carried out with members of the Sikh community caring for a person with dementia. Previous research with South Asian carers of people with dementia has reported problems with both access to, and use of, health and social care services namely due to cultural and language barriers within existing services. The research reported in this article sought for an in-depth understanding of the experiences of Sikhs caring for their family member with dementia. The aim of the research was to explore how migration experiences and life histories impact on perceptions and experiences of caring for a family member with dementia for Sikhs living in Wolverhampton in the West Midlands, United Kingdom. The research, undertaken by the author, applied a biographical approach using narrative interviews. Twelve Sikh carers of a family member with dementia were interviewed. Findings highlighted that migration experiences and migration identities are important for understanding participants’ experiences of services and experiences of caring for a family member with dementia. Person-centred dementia care as a model for practice highlights the importance of understanding life histories to support people to live well with dementia, including their family carers. This paper reinforces this message, demonstrating the impact of specific migration experiences on the experiences of caring for a family member with dementia.