In Stewart v Secretary of State for Work and Pensions [2011] EWCA Civ 907 (29 July 2011), the refusal to provide a funeral payment from the Social Fund to a prisoner because she was not in receipt of a qualifying benefit was indirectly discriminatory under Article 14 and Article 1 of Protocol No. 1 of the ECHR, but the Court was satisfied that the Secretary of State had established a rational justification for the discriminatory treatment (click here for transcript).