This commentary considers the decision of the Supreme Court (SC) in Greater Glasgow Health Board v. Doogan and Others, which concerns the definition of ‘participate’ in the context of abortion and the conscientious objection of healthcare professionals due to their religious beliefs. It is argued that the SC was correct in affirming the definition of participate as articulated by Lord Keith in Janaway v. Salford Area General Authority. The protection of conscientious objection, under Article 9 of the European Convention on Human Rights, is considered. The discussion in this commentary, however, is limited to religious belief and does not consider the wider ambit of Article 9, such as nonreligious philosophical beliefs.