What is the purpose of the phrase "f...ing pope", shouted across a busy newsroom? A Catholic sub-editor at the Times newspaper felt that the defacto purpose of the phrase was "harassment on grounds of religion", with the (intended? predictable?) effect of creating an adverse working environment for himself and other Catholics. There is an interesting question here about conscious motivation and deliberate action.
The Employment Tribunal and the Employment Appeal Tribunal disagreed. If Mr Heafield experienced the environment as adverse, that was unreasonable of him. They didn't ask - but we might well ask - what was Mr Heafield's real purpose for pursuing the case?
Although some Renaissance popes allegedly led active sex lives (appointing their "nephews" to prominent positions in the Church), the term "f...ing pope" is probably regarded by Catholics and non-believers alike as a term that doesn't refer to any living person. (Bertrand Russell's Theory of Descriptions could be relevant here.)
Screaming pope maybe. Would it count as "harassment on grounds of
religion"to display a reproduction of Francis Bacon's famous painting?
Daniel Barnett, Harassment on Grounds of Religion (14 February 2013)