St Christopher's Fellowship v Walters-Ennis

St Christopher's Fellowship v Walters-Ennis

The Employment Tribunal erred in law by finding race discrimination in the Southend recruitment case, as its reasoning was inconsistent with its findings in the Kayleigh Morrison case; the factual differences were insufficient to justify shifting the burden of proof, and the respondent's genuine, though mistaken,...

Source-derived case information.

Parties
Appellant: St Christopher’s Fellowship; Respondent: Mrs Barbara Walters-Ennis
Jurisdiction
England and Wales
Judgment Date
30 July 2010
Procedural Posture
Civil Appeal / Judgment on Appeal
Outcome
appeal allowed; race discrimination complaint dismissed
Legal Topics
Direct Race Discrimination, Burden of Proof, Constructive Unfair Dismissal, Recruitment Procedures
Employment Law Discrimination Law Direct Race Discrimination Burden of Proof Constructive Unfair Dismissal Recruitment Procedures

Source-derived case record

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Parties

St Christopher’s Fellowship

Appellant

Mrs Barbara Walters-Ennis

Respondent

Procedural Posture

Civil Appeal / Judgment on Appeal

Legal Issues

  1. 1 Whether the Employment Tribunal properly understood and applied the statutory burden of proof in a case of alleged direct race discrimination under s54A(2) of the Race Relations Act 1976
  2. 2 Whether the facts proved could lead to a conclusion of race discrimination in the absence of an adequate explanation
  3. 3 Whether the Employment Tribunal's findings were internally consistent regarding similar recruitment situations

Ratio Decidendi

The Employment Tribunal erred in law by finding race discrimination in the Southend recruitment case, as its reasoning was inconsistent with its findings in the Kayleigh Morrison case; the factual differences were insufficient to justify shifting the burden of proof, and the respondent's genuine, though mistaken, belief about relationships did not amount to racial grounds.

Court Disposition

appeal allowed; race discrimination complaint dismissed

Orders

  • The appeal is allowed.
  • The only remaining race discrimination complaint is dismissed.