Trans persons and non-binary persons

1. Overview

This chapter covers trans and non-binary issues and explains gender critical views.  This is an area which has become characterised by strong views, and sometimes a lack of respectful debate, often on social media.  In the 2022 census, just under 20,000 people described themselves as trans, or having a trans history (equating to 0.44% of the population over 16).[1]

It is split into sections as follows:

  1. Overview

  2. Introduction

  3. A trans person and the law

  4. Non-binary persons

  5. Gender/sex/biological identity

  6. Gender critical views

  7. Medical treatment for trans persons

  8. Discrimination and hate crime

  9. Trans persons in a court or tribunal

  10. Non-binary persons in court

  11. Trans persons in prison

  12. Definitions

2. Introduction

Someone who identifies as “trans” considers they have a different gender identity from their biological sex. Some organisations and individuals refer to ‘gender expression’ rather than gender identity.

Some do not identify as one or other gender or identify as having a fluid gender identity. When someone does not identify as either gender that is generally referred to as “non-binary”. Non-binary is not recognised in law as a separate category of gender or sex (for example, in that a birth certificate or passport must have a person’s gender as either male or female).[2] However non-binary persons are included within the definition of transgender identity for the purposes of the Hate Crime and Public Order (Scotland) Act 2021.  Sometimes “trans” is used to include non-binary persons.

Trans and non-binary identities are separate from sexuality. Whilst some trans persons identify as gay (that is, will seek same-sex relationships as within their acquired gender identity), sexual orientation is a separate part of someone’s identity. Sexual preferences are a different personal issue to gender identity (and are also two separate protected characteristics under the Equality Act 2010, being sexual orientation and gender reassignment).

A list of terms that might be used, or referred to, are found at the end of the chapter. Judges should note that some terms listed are controversial. As the Inner House has observed

The issues which surround the whole subject of gender reassignment, gender Identity, and gender recognition are difficult and sensitive. It is not always easy for the law to keep pace where societal attitudes and understandings are in a state of flux…[3]

It is also an area where there can be intense scrutiny over the words and phrases used by judges.

It is also important to acknowledge what are called “gender critical views or beliefs”. There are variations in what that phrase might mean to different individuals, but it essentially criticises the ability to change sex, it being argued that sex is a matter of biology rather than identity, and sex and gender cannot be conflated. Gender critical beliefs have been held to be protected under the Equality Act 2010.

Given the political debate around this issue, the fluctuating legal position and the emotive issues involved, care is required. If a judge does not refer to a person in accordance with their own chosen gender identity, there is a risk of failing to respect the protected characteristic of gender reassignment under the Equality Act 2010, and also of alienating that person from the court process.   On the other hand, judges will be aware of high-profile cases with an accused identifying as trans (without a Gender Recognition Certificate). There have been sensitivities with complainers and others if a judge or others in the court refer to the accused using the accused’s preferred pronouns. Ultimately, whilst judges should, if possible, accommodate individuals’ wishes and preferences, where that does not impinge on the rights of others, there may be times where a judge must deal with matters in accordance with a person’s legal sex.

Judges should note that if a person has a Gender Recognition Certificate, that has the effect of changing someone’s gender.[4] In those circumstances, the person’s gender before the court is that of the assigned gender (but see footnote 239 above).

3. A trans person and the law

The Gender Recognition Act 2004 was introduced as a result of a decision of the European Court of Human Rights.[5] Relatively small numbers of Gender Recognition Certificates (GRC) are issued each year.[6] The issuing of a GRC changes someone’s gender to the acquired gender.[7] Whilst there has been the ability to apply for a GRC for some time, there are outstanding legal questions as to the interaction between the issuing of a GRC and the Equality Act 2010.[8] This section should be read with that in mind.

Not everyone who identifies as trans seeks treatment or applies to legally change their gender (by obtaining a GRC).[9] There may be many personal reasons for not doing so. Trans groups report the process as difficult to navigate, and intrusive. Someone without a GRC but identifying as trans will still have the protection offered by the Equality Act 2010 (so long as they can meet the protected characteristic of being an individual who is ‘proposing to undergo, is undergoing or has undergone a process or part of a process to reassign their sex’). Someone cannot apply for a GRC until they have lived in their acquired gender for two years.

Accordingly, that gives a period where a trans person is unable to legally change their gender but may present to the outside world as the other gender. That may be consistent, or it may fluctuate. It could be easier for a trans person to identify as their preferred gender in a supportive social situation than it is for them to appear as the other gender in their workplace or around certain people or situations. It may depend on context and how confident an individual feels.  Those factors are likely to vary over time.

Accordingly, noting the requirement to have lived in the acquired gender for two years before an application can be made for a GRC, someone may present in court in the opposite gender to their birth sex. Such a person would not have the protection of a GRC (so accordingly their gender would be in accordance with their birth sex) but would be protected under the Equality Act 2010 under the protected characteristic of gender reassignment, and must not be subject to harassment, discrimination or victimisation.

More than one protected characteristic under the Equality Act 2010 can apply at any one time. An example might be someone protected under the characteristics of both race and disability. Someone identifying as trans might have the protection of both gender and trans. For example, if a trans person’s biological sex is female, and they identify as male but without a GRC, it is likely that person will have both the protected characteristics of being female and of gender reassignment (so long as they can meet the protected characteristic for gender reassignment).

If someone has, or is applying for a Gender Recognition Certificate, it is an offence for someone who has obtained that information in an official capacity (such as an employer or public official) to disclose it to others.[10] There are various exemptions, including disclosure by virtue of a court order, and disclosure for the purpose of preventing or investigating crime.[11]

Judges will be aware of the proposed changes in Scotland, set out in the Gender Recognition Reform (Scotland) Bill. The Bill, as passed by the Scottish Parliament, proposed various changes to the process, including altering the age at which a GRC could be applied for, shortening the period required to live in the acquired gender, and removing the need to have a diagnosis of gender dysphoria. The Bill was subsequently blocked by an order made by the UK Government and is unlikely to become law in the near future.[12]

Some of the definitions within the Equality Act 2010 have come before the courts in a number of cases.[13] As indicated, this includes (at the time of writing) a case before the UKSC.[14] Separately, the Equalities and Human Rights Commission has made recommendations to the UK Government on the issue of amendments to the Equality Act 2010 (relating to the definitions of ‘sex’).[15] Accordingly this is a dynamic area of law.

4. Non-binary persons

A non-binary identification is where a person does not identify as either male or female, or may have a changing identification between the two. It is not known how many persons would identify themselves as non-binary in Scotland, although for the first time the 2022 census allowed participants to identity as non-binary.[16]

As previously set out, there is no legal recognition of non-binary as an alternative to male or female gender.[17] A high percentage of non-binary people report feeling their gender identity is not valid.[18]

The Employment Tribunal has found that a biological male transitioning, but unsure as to whether they would have a gender fluid or a female identity in the longer term, was nevertheless protected under the characteristic of gender reassignment.[19] Whilst this is not binding, and was based on the particular facts, it may be a helpful illustration of the issues.

“Transgender identity” in the Hate Crime and Public Order (Scotland) Act 2021 is defined to include non-binary identity.[20] Broadly speaking the Act creates aggravations by prejudice to offences and stirring up hatred offences, as well as a requirement for the police to record and report on non-crime “hate incidents”.

5. Gender/sex/biological identity

Whether the word “gender” is used, as opposed to “sex” or “biological sex”, can be controversial.  Many people, particularly younger people, use such phrases to describe someone’s internal sense of their identity irrespective of the legal position.

6. Gender critical views

For some, gender is a social construct rather than a matter of biology. Some believe that biological sex is immutable and cannot be changed. These views are often referred to as ‘gender critical’ views, (although there can be a range of views within that description). Such views include that sex cannot be changed and is a matter of biology, that sex is distinct from gender identity, and around concerns that single sex spaces/sports should not include those identifying as female if biologically male, whether or not the individual has a GRC assigning their gender as female.

Gender critical views have been recognised as a philosophical belief, and thus protected under the Equality Act 2010.[21]

7. Medical treatment for trans persons

Treatment is available on the NHS in Scotland for those wishing to change their gender, including for young people.[22] However, many persons who identify as trans do not seek medical treatment, some citing issues around accessing treatment.

Some trans people do not consider medical treatment is required. Medical treatment, such as hormone treatment, is not required to bring a trans person within the scope of the protected characteristic of gender reassignment under the Equality Act 2010 although a diagnosis of gender dysphoria is required to obtain a GRC.

8. Discrimination and hate crime

Trans persons report experiencing high levels of prejudice and discrimination. In a report by the Equalities Network on hate crime (across a number of sexuality and gender identity characteristics) trans persons reported the highest level of hate crime.[23]

Crown Office statistics suggest such crime (or the reporting of such crime) is on the rise.  In 2021-22 there were 84 incidents reported with an aggravation of transgender identity, an increase of 87% on the previous year. Crown Office note this is “the highest number of such charges reported since the legislation introducing this aggravation came into force in 2010.”[24]

Judges are familiar with the concept of explaining in what way an aggravation is taken into account when sentencing.[25] Research suggests that an explanation as to how the aggravation has been taken into account may be important for the complainer to understand the sentence imposed.[26]

“Transgender identity”[27] is a protected characteristic in terms of the Hate Crime and Public Order (Scotland) Act 2021. Broadly speaking the Act creates aggravations by prejudice to offences and stirring up hatred offences, as well as a requirement for the police to record and report on non-crime “hate incidents”.

9. Trans persons in a court or tribunal

Judges may wish to note the following points:

  • The name and pronouns by which a person is referred to or called can be very important to a trans person. It might be seen as a sign of disrespect if someone does not refer to them by their chosen identity;

  • Often the question of gender identity is not truly relevant to the issue at hand; for example, so long as there is no dispute about the identity of a witness, if a witness wishes to be referred by a male pronoun despite having a female appearance, that may not require any further questions by the court or tribunal. Accordingly where someone’s gender identity is not a material issue, judges may wish to take the approach of accommodating those preferences without enquiry into, for example, the legal position;

  • In evidential hearings, as with any collateral matter, take care to ensure matters do not stray beyond what is necessary to determine the issues that are relevant and in dispute;

  • Judges should be alert to any attempts to ‘out’ someone. In the limited number of cases where gender identification is relevant, the court should be alert to any questions that might be demeaning or insulting or interpreted as such, given the need for everyone in court to be treated with courtesy and dignity. If the question is relevant, judges should ask for it to be rephrased;

  • If referring to someone in a way that goes against their own gender identity (in circumstances where the person has not legally changed their gender and name), be mindful that of the risk of alienating them from the court process;

  • Notwithstanding that, respecting someone’s chosen gender identity must be balanced against the impact on others. Whilst the numbers of trans persons appearing in court as an accused person are likely to be small, difficult issues can arise, particular in cases involving sexual allegations;

  • In criminal trials, there may be a time lag between the alleged events and the trial. If so, and gender identification has altered in the intervening period, and is likely to feature in the case, encourage a joint minute agreeing the facts around the individual’s gender identity, whether that is of a witness or the accused.[28] Such a joint minute might address any differences in physical appearance between the alleged events in question and the trial, and/or agree identification.  That may avoid the issue of gender identification becoming a distraction;

  • Consider an early discussion as to how someone should be referred to in court if the matter is likely to proceed to an evidential hearing. Some judges have found setting out the general expectation that the court will respect the chosen identity where possible (irrespective of the individual’s legal position) has prevented the matter becoming a distraction at trial or proof;

  • In some circumstances the court may have to consider the legal position of the accused’s gender, particularly where others are affected. That might include the ability of the press to understand any trans issue and accurately report the facts;

  • The court should always put witnesses in the position of giving their best evidence. As in any case (for example a fraud where an accused has used multiple identities) witnesses should give their evidence referring to the accused in the way they knew that person, including by the name they knew them as. Placing additional or artificial barriers on a witness is likely to detract from their ability to give best evidence. Accordingly, complainers giving evidence in trials should not be required to call an accused ‘she’ if they knew the accused as a male;

  • In sexual assault cases there is a likely to be heightened sensitivity, particularly when a female complainer knew the accused as a male and the male is now identifying as a female.   Ensure that any such cases are properly case managed and consider a sentencing statement so that any remarks in court are more likely to be accurately reported.

  • Some of the sensitivities and issues that may arise are dealt with by academic Claire O’Brien in this blog, which also highlights the international law dimension when considering offences of violence against women.

A guiding principle is likely to be that witnesses should always give their evidence without hindrance, and by referring to the accused as that person was known to the witness.

10. Non-binary persons in court

Much of what has been said relative to trans persons in court may also apply to non-binary persons. Some additional points include:

  • Many non-binary and trans people do not wish to use Mr/Mrs/Ms but use Mx as a gender-neutral alternative (pronounced “mucks”). Many people now identify their gender on emails (where e.g. him/he after their name) and use gender neutral terms (e.g. they instead of I). There is no accepted one definition or use of gender-neutral terms;[29]

  • A gender fluid person may identify as male appearance on some occasions, and female on others;

  • Judges may wish to refer to jurors as a collective using the term ‘Members of the jury’ rather than ‘Ladies and gentlemen’ (see also the Gender chapter relative to this).

11. Trans persons in prison

The question of in which prison facility a person is held is not a matter for the judiciary but for the Scottish Prison Service (in a similar way to how the prison service might respond to a person’s disability or other characteristic).[30]

The SPS policy considers individual cases, which may allow a trans person to be placed in a prison in accordance with the gender they identify with.[31]

12. Definitions

Some of these definitions are contested. Judges are given these definitions to assist their understanding should they be used in court. Accordingly, the inclusion of these definitions does not suggest that they should be used more widely, or that the meaning is settled.

Cis/cisgender

Used by trans groups and others to denote someone who is not transgender and identifies with their sex at birth. However, many women’s groups object to this definition, noting they identify as females or as women.

Cross-dressing

The wearing clothes, make-up, or other accessories generally associated with the opposite gender; not now often used

Deadname

The name that a trans person had in the other gender and no longer uses.

Gender dysphoria

A medical/clinical term referring to difficulties a person has where they identify as a different gender from their biological sex.

Gender expression

The way that someone might express themselves in a way that is viewed as masculine or feminine by clothing or behaviours.

Gender identity

Refers to an internal sense of gender and whether (irrespective of the legal position) someone identifies themselves as one or other gender, or a fluctuating gender, or no gender.

Gender reassignment

The legal term used in the Equality Act 2010 as a protected characteristic, but also used to refer to the process of someone changing their name, pronoun and living in their self-identified gender, including with legal recognition (without necessarily hormonal or surgical treatment).

Non-binary

Where someone identifies as either having a gender which is in-between or beyond the two categories of ‘man’ and ‘woman’, or fluctuating between ‘man’ and ‘woman’, or as having no gender, either permanently or some of the time.

Trans/transgender

Someone whose gender identity or gender expression does not fully correspond with the sex they were assigned at birth.

Trans man

A person who was assigned female at birth but has a male gender identity and therefore transitions to live as a man. Sometimes also referred to in the trans community as ‘person with a trans history’.

Trans woman

A person who was assigned male at birth but has a female gender identity and therefore transitions to live as a woman. Sometimes also referred to in the trans community as ‘person with a trans history’.

Transphobia

Prejudice or discrimination again trans persons​​

Transitioning

The process that a trans person takes to live in the gender they now wish to. This might include medical interventions, such as hormone treatment and changing their gender legally, although others consider themselves transitioning without any such steps.

Transsexual

Used in the Equality Act 2006 to describe a person undergoing gender reassignment but has otherwise been largely replaced by ‘trans’ and generally no longer used by the trans community.


[1] The exact number was 19,990.  The question included those who identify as non-binary (9,030 identified as non-binary).  Most of those identifying as trans or having a trans history were between 16 to 34 (46.1% were 16 to 24 and 26% were 25 to 34).
[2] See R (on the application of Elan-Cane) (Appellant) v Secretary of State for the Home Department (Respondent) [2021] UKSC 56. However, a non-binary identity could be protected under the Equality Act 2010 on particular facts; see the Employment Tribunal decision Taylor v Jaguar Land Rover Limited [2020] 9 WLUK 200 The Scottish Government set up a Non-Binary People’s Working Group, which reported in 2022, and made 35 recommendations. Those recommendations included data collection and reforms in areas including health care, sport and education. The group also recommended research on legal recognition of those who identify as non-binary (Non-Binary Equality Working Group: Report and Recommendations). The Scottish Government has accepted some of the recommendations (Non-Binary Equality Working Group Recommendations: Scottish Government Response.
[3] For Women Scotland v Scottish Ministers, [2023] CSIH 37 at para 30.
[4] The UKSC has a case before it which raises how the law should treat someone who has a Gender Recognition Certificate, and the interaction with the Equality Act 2010. Pending the UKSC decision, judges should note that a Gender Recognition Certificate means “the person’s gender becomes for all purposes the acquired gender” (section 9(1) of the Gender Recognition Act 2004).
[5] In short, a Gender Recognition Certificate changes someone’s gender. The current law on Gender Recognition Certificates is governed by the Gender Recognition Act 2004, a UK Act introduced to respond to the European Court of Human Rights’ decision in Goodwin v UK [2002] 7 WLUK 347. An application is put before the Gender Recognition Panel. There must be medical evidence of gender dysphoria, and the person must have lived in proposed gender for 2 years and make a declaration of intent that they will live in their acquired gender for the rest of their life. Note that there are prohibitions in relation to disclosure of certain information around a Gender Recognition Certificate, with some exceptions including for certain legal matters; see section 22 of Gender Recognition Act 2004.
[6] 443 applications in 2019/20 and 466 in 2020/21. Most applications are granted: 93.1% in 2019/20 and 95.6% in 2020/21 Gender Recognition Certificate: Applications and Outcomes.
[7] Section 9(1) of the Gender Recognition Act 2004 states that “where a full gender recognition certificate is issued to a person, the person’s gender becomes for all purposes the acquired gender (so that, if the acquired gender is the male gender, the person’s sex becomes that of a man and, if it is the female gender, the person’s sex becomes that of a woman).”
[8] See footnote 239.
[9] A 2018 UK Government consultation noted the differences between the numbers of persons identifying as trans and the number of GRCs issued, and concerns that the difference was because many found the process of obtaining a GRC too bureaucratic, intrusive and expensive.
[10] Section 22 of Gender Recognition Act 2004.
[11] The list of exemptions if found in section 22(4) of the Gender Recognition Act 2004.
[12] The UK Government made an order under section 35 of the Scotland Act 1998. A challenge to that order was refused in the Outer House: see decision of Lady Haldane in the Outer House The Scottish Ministers [2023] CSOH 89. The Scottish Government indicated it would not reclaim (appeal) that decision Scottish Government Response to the Section 35 Order Judicial Review. The Bill does not become law unless the section 35 order is revoked.
[13] For example Fair Play for Women Ltd v Registrar General for Scotland [2022] S.C. 199 and For Women Scotland v The Scottish Ministers [2023] CSIH 37.
[14] The Inner House have granted permission to appeal to the UKSC in the case For Women Scotland v The Scottish Ministers [2023] CSIH 37 (concerning guidance regarding representation on public bodies, and whether someone holding a GRC so that their acquired gender was female would also be protected in law under the protected characteristic of gender as a female) on the basis that the interaction between the Gender Recognition Act 2004 and the Equality Act 2010 involves points of law of general public importance.  The case is due to be heard in November 2024.
[15] See letter of 21 February 2023 Clarifying the Definition of ‘Sex’ in the Equality Act | EHRC.
[16] See Scotland's Census 2022: Sex Question Guidance. At the time of writing, the full results of the 2022 census are not known. The response level to the census was lower than the previous Scottish census in 2011 (89% participation as opposed to 95% in 2011), and the English & Welsh census in 2021 (97 % participation) Census: Scotland's Population Grew to Record High - BBC News. The wording of guidance or wording in the census has been the subject of court action both in England & Wales and in Scotland.
[17] See R (Castelluci) v The Gender Recognition Panel and the Minister for Women and Equalities [2024] EWHC 54 where the Divisional Court in England held there was no power to issue a Gender Recognition Certificate recording gender as ‘non-binary’. See also UKSC decision in R (on the application of Elan-Cane) (Appellant) v Secretary of State for the Home Department (Respondent) [2021] UKSC 56 regarding the recording of gender on a passport. See however footnote 255: a non-binary person is included within the definition regarding transgender identification for the purposes of the Hate Crime and Public Order (Scotland) Act 2021.
[18] 84 % in a survey by Scottish Trans and Equality Network Non-binary people’s experiences in the UK, 2015, based on an on-line survey of 1,401 but a sample size of 895
[19] Taylor v Jaguar Land Rover Limited [2020] 9 WLUK 200.
[20] Section 11(7) of the Hate Crime and Public Order (Scotland) Act 2021 defines this as “(7) A person is a member of a group defined by reference to transgender identity if the person is— (a) a female-to-male transgender person, (b) a male-to-female transgender person, (c) a non-binary person, (d) a person who cross-dresses, and references to transgender identity are to be construed accordingly.”
[21] See decision of the Employment Tribunal in Forstater v CGD Europe and others [2022] I.C.R. 1.
[22] Treatment is available through NHS health boards; see Gender Reassignment Protocol which provides arrangements for the Sandyford Clinic to provide services to those in other health board areas. There have been criticisms by some over the waiting lists for such services. Following the CASS Review, it is understood that puberty blockers will not be prescribed to any new young people as patients.
[23] The number of persons identifying as trans that participated in the survey was relatively low, at 198 valid responses from 1,516 respondents (Scottish LGBTI Hate Crime Report, Equality Network, 2017). The percentage of participants reporting hate crime who participated in the survey was 65 % for those identifying as lesbians, 66 % for male gay respondents and 53 % of bisexual respondents, although participation in the survey may not represent an even split of those identifying.
[24] Hate Crime in Scotland, COPFS, 2021-22, published 14 June 2022.
[25] Sections 1 and 2 of the Offences (Aggravation by Prejudice) (Scotland) Act 2009 requires a court to record the aggravation and take the aggravation into account when sentencing, explaining the reasons for the difference in sentencing taking account of the aggravation, or where there is no difference in sentencing, reasons why there is no difference.
[26] Scottish LGBTI Hate Crime Report, Equality Network, 2017 recommended that there was more transparency in sentencing, explaining how the prejudice aggravation had been taken into account to allow complainers to understand the sentence Transparency is needed in sentencing, including clarification of the prejudice aggravation element (at page 86) .
[27] Section 11(7) of the Hate Crime and Public Order (Scotland) Act 2021 defines this as “(7) A person is a member of a group defined by reference to transgender identity if the person is— (a) a female-to-male transgender person, (b) a male-to-female transgender person, (c) a non-binary person,(d) a person who cross-dresses, and references to transgender identity are to be construed accordingly.”
[28] Judges may find it helpful to have note of the Crown Office and Procurator Fiscal policy; Guidance for Prosecutors in Relation to Transgender Accused | COPFS
[29] See discursive article on BBC website: Beyond 'He' and 'She': The rise of Non-Binary Pronouns.
[30] It would only be a matter for the judiciary if there was a challenge to a decision made by the SPS before the court.
[31] Management of Gender Diverse People in Custody Operational Guidance 2024 states “When a transgender person is admitted into custody, they should be considered on an individual basis as far as possible. However, if placing them in accommodation which accords with their affirmed gender gives rise to unacceptable risks that cannot be mitigated or this risk is as yet unknown, they will initially be located in an establishment that aligns with their sex assigned at birth. If a transgender woman meets the Violence Against Women and Girls (VAWG) criteria (see Annex 1…), they will be admitted to accommodation in the male estate.”