Madden v Preferred Technical Group CHA Ltd & Anor [2004] EWCA Civ 1178 (27 August 2004)

Madden v Preferred Technical Group CHA Ltd & Anor [2004] EWCA Civ 1178 (27 August 2004)

The tribunal was entitled to dismiss the appellant's claims of direct race discrimination and victimisation under the Race Relations Act 1976, having found that less favourable treatment was not causally connected to race or protected act but arose from poor working relations, and provided adequate reasons for not drawing inferences of discrimination.

Citation
[2004] EWCA Civ 1178
Parties
Appellant: George G Madden; 1st Respondent: Preferred Technical Group Cha Limited; 2nd Respondent: Michael Guest
Jurisdiction
England and Wales
Judgment Date
27 August 2004
Procedural Posture
Appeal From Employment Appeal Tribunal / Court of Appeal Judgment
Outcome
Appeal dismissed
Legal Topics
Race Discrimination, Victimisation, Unfair Dismissal, Wrongful Dismissal, Protected Act, Comparators, Inference Drawing
Employment Law Discrimination Law Race Discrimination Victimisation Unfair Dismissal Wrongful Dismissal Protected Act Comparators +1 more

Case Brief

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Parties

George G Madden

Appellant

Preferred Technical Group Cha Limited

1st Respondent

Michael Guest

2nd Respondent

Procedural Posture

Appeal From Employment Appeal Tribunal / Court of Appeal Judgment

Legal Issues

  1. 1 Whether the appellant was subjected to direct race discrimination under Race Relations Act 1976
  2. 2 Whether the appellant was victimised for performing a protected act
  3. 3 Whether less favourable treatment was attributable to race or protected act

Ratio Decidendi

The tribunal was entitled to dismiss the appellant's claims of direct race discrimination and victimisation under the Race Relations Act 1976, having found that less favourable treatment was not causally connected to race or protected act but arose from poor working relations, and provided adequate reasons for not drawing inferences of discrimination.

Court Disposition

Appeal dismissed

Orders

  • Appellant's claims of direct discrimination and victimisation under Race Relations Act 1976 dismissed
  • No order for rehearing by fresh tribunal