Mecca Leisure Group Plc v Chatprachong [1993] UKEAT 654_90_1301 (13 January 1993)

Mecca Leisure Group Plc v Chatprachong [1993] UKEAT 654_90_1301 (13 January 1993)

The appeal succeeded in part: the Tribunal erred in law by not identifying a comparator or the timing of the alleged less favourable treatment regarding training and promotion. There was no evidence that the respondent was treated less favourably than others in similar circumstances. The findings of racial abuse were upheld, but the claim regarding denial of training/promotion failed. The dismissal was not on racial grounds.

Citation
[1993] UKEAT 654_90_1301
Parties
Appellant: Mecca Leisure Group Plc; Respondent: Mr Chatprachong; Respondent: Commission for Racial Equality
Jurisdiction
United Kingdom
Judgment Date
13 January 1993
Procedural Posture
Appeal / Judgment on Appeal From Industrial Tribunal
Outcome
Appeal allowed in part
Legal Topics
Racial Discrimination, Dismissal, Equal Opportunities, Training and Promotion, Race Relations Act 1976
Employment Law Equality Law Racial Discrimination Dismissal Equal Opportunities Training and Promotion Race Relations Act 1976

Case Brief

Summary, issues, holding and outcome

More case intelligence is available

Unlock the full research layer for this judgment.

Full judgment text Downloadable case file Legal principles 3 Authorities cited 11 Party arguments 2
Sign in to unlock

Parties

Mecca Leisure Group Plc

Appellant

Mr Chatprachong

Respondent

Commission for Racial Equality

Respondent

Procedural Posture

Appeal / Judgment on Appeal From Industrial Tribunal

Legal Issues

  1. 1 Whether the respondent was unlawfully discriminated against on racial grounds contrary to the Race Relations Act 1976 in relation to dismissal, racial abuse, and denial of training/promotion opportunities.

Ratio Decidendi

The appeal succeeded in part: the Tribunal erred in law by not identifying a comparator or the timing of the alleged less favourable treatment regarding training and promotion. There was no evidence that the respondent was treated less favourably than others in similar circumstances. The findings of racial abuse were upheld, but the claim regarding denial of training/promotion failed. The dismissal was not on racial grounds.

Court Disposition

Appeal allowed in part

Orders

  • Finding of racial abuse upheld; appeal on training/promotion issue allowed; no breach of s.4(2)(b) Race Relations Act 1976; dismissal claim fails.