It can be very easily spoofed, and very easily disabled. So, yes, don't trust it and certainly don't rely on it entirely.
When I've absolutely needed to know the user's previous page, I've passed it either as a session/cookie variable, or in the URL (could base64_encode to shorten it) i.e. on each page load I set the current page URI in the session, or append it to all relevant hyperlinks on the page. These methods are just as untrustworthy, but at least it means that you can be fairly sure you'll be able to access the information.