The case of Eweida, Ladele and McFarlane v. United Kingdom2 presented the latest instance in which the European Court of Human Rights (ECtHR) was confronted with the vexing task of reconciling the right to religion with the seemingly contradictory right to equality. The aforementioned case pertained to the right of Christian believers to refuse counseling or marriage registration services to homosexual couples. When caught on the horns of a dilemma in similar cases of this nature, the ECtHR attempted to resolve this conundrum by resorting to the "doctrine of proportionality" and the "margin of appreciation" tests.3 Somewhat predictably, therefore, the ECtHR resorted to similar doctrinal tools in the Ladele decision as well. However both the doctrinal frameworks of proportionality and margin of appreciation are susceptible to critique for their failure to adequately resolve the contentious issues raised.4