Williams v HM Prison Service [2002] EWCA Civ 809 (3 May 2002)

Williams v HM Prison Service [2002] EWCA Civ 809 (3 May 2002)

The Employment Tribunal gave adequate reasons, applied the correct legal principles, and made findings supported by evidence. There was no evidence of race discrimination or victimisation, and the use of objective criteria was appropriate. The Tribunal was entitled to find that the applicant was not treated less favourably on racial grounds or due to protected acts.

Citation
[2002] EWCA Civ 809
Parties
Applicant: Williams; Respondent: HM Prison Service
Jurisdiction
England and Wales
Judgment Date
03 May 2002
Procedural Posture
Application for Permission to Appeal (civil) / Application for Permission to Appeal to Court of Appeal From Employment Appeal Tribunal Decision
Outcome
Application for permission to appeal refused
Legal Topics
Race Discrimination, Victimisation, Employment Tribunal Procedure, Reasons for Decision, Comparators in Discrimination Cases
Employment Law Discrimination Law Race Discrimination Victimisation Employment Tribunal Procedure Reasons for Decision Comparators in Discrimination Cases

Case Brief

Summary, issues, holding and outcome

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Parties

Williams

Applicant

HM Prison Service

Respondent

Procedural Posture

Application for Permission to Appeal (civil) / Application for Permission to Appeal to Court of Appeal From Employment Appeal Tribunal Decision

Legal Issues

  1. 1 Whether the Employment Tribunal erred in law in dismissing claims of race discrimination and victimisation
  2. 2 Whether the Tribunal failed to give adequate reasons for its decision
  3. 3 Whether the Tribunal failed to apply the correct legal tests under the Race Relations Act 1976, including use of comparators and proper analysis of 'sift criteria'

Ratio Decidendi

The Employment Tribunal gave adequate reasons, applied the correct legal principles, and made findings supported by evidence. There was no evidence of race discrimination or victimisation, and the use of objective criteria was appropriate. The Tribunal was entitled to find that the applicant was not treated less favourably on racial grounds or due to protected acts.

Court Disposition

Application for permission to appeal refused

Orders

  • Application refused