aims. This principle could mean requiring workers to appear and behave in a certain way: not only on the obvious grounds of hygiene or safety, but simply as part of company strategy.

The Euro-pronouncement seems almost diametrically opposed to a ruling issued by the American Supreme Court exactly a year ago. In a decision which Judge Antonin Scalia described as “really easy” the Court found that the clothing store Abercrombie and Fitch had been at fault in denying a job to a headscarved woman, even though she had not spelled out the fact that covering her head was part of her Muslim belief. The headscarf was considered out of step with a “look” that the store was projecting at the time, although it has since changed its policy. Inif production were interrupted. As you would expect, Cargill is more interested in getting cattle carcasses efficiently sliced up than in the finer points of Islamic supplication.

On the European side, confusion is created by the fact that there are two at least two transnational courts with some say in this area: the ECHR, an organ of the 47-nation Council of Europe which adjudicates questions of basic human rights, and the ECJ which enforces the laws and regulations of the 28-member European Union.

Marco Ventura, an Italian scholar who runs the Bruno Kessler Foundation, a religious-studies centre in Trento, predicts that this week's ruling, albeit very important, will not be the European judiciary's last word. "European law courts are becoming a trans-national laboratory combining religious precepts, legal mechanisms, private interests