Fox v Rangecroft & Anor

Fox v Rangecroft & Anor

The claimant failed to prove any primary facts from which the Tribunal could infer sex discrimination; therefore, the burden of proof did not shift under section 63A, and the Tribunal's findings were not tainted by legal error.

Parties
Claimant/appellant: Angela Fox; Defendant/respondent: Michael Rangecroft; Defendant/respondent: Elmbridge Borough Council
Jurisdiction
England and Wales
Judgment Date
13 July 2006
Procedural Posture
Civil Appeal / Appeal From Employment Appeal Tribunal
Outcome
Appeal dismissed
Legal Topics
Sex Discrimination, Burden of Proof, Employment Tribunal Procedure
Employment Law Discrimination Law Sex Discrimination Burden of Proof Employment Tribunal Procedure

Case Brief

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Parties

Angela Fox

Claimant/appellant

Michael Rangecroft

Defendant/respondent

Elmbridge Borough Council

Defendant/respondent

Procedural Posture

Civil Appeal / Appeal From Employment Appeal Tribunal

Legal Issues

  1. 1 Whether the Employment Tribunal misapplied section 63A of the Sex Discrimination Act 1975 regarding the burden of proof in discrimination claims
  2. 2 Whether the findings of fact by the Employment Tribunal were tainted by legal error under section 63A

Ratio Decidendi

The claimant failed to prove any primary facts from which the Tribunal could infer sex discrimination; therefore, the burden of proof did not shift under section 63A, and the Tribunal's findings were not tainted by legal error.

Court Disposition

Appeal dismissed

Orders

  • Appeal dismissed
  • No further action ordered