HCA International Ltd v. BPP Law Courses Ltd [2003] UKEAT 0306_03_1404 (14 April 2003)

HCA International Ltd v. BPP Law Courses Ltd [2003] UKEAT 0306_03_1404 (14 April 2003)

The tribunal was entitled to preserve the confidentiality of individual tutors' identities, as disclosure of their names was not necessary for the fair disposal of the applicant's discrimination claims. The appeal did not raise a question of law justifying intervention.

Citation
[2003] UKEAT 0306_03_1404
Parties
Applicant: Mr A J Engel; Respondent: BPP Law Courses Ltd
Jurisdiction
United Kingdom
Judgment Date
14 April 2003
Procedural Posture
Employment Appeal Tribunal / Interlocutory Appeal Against Procedural Orders
Outcome
Appeal dismissed subject to agreed arrangements between parties.
Legal Topics
Disclosure of Documents, Confidentiality, Race Discrimination, Sex Discrimination, Procedural Fairness
Employment Law Discrimination Law Disclosure of Documents Confidentiality Race Discrimination Sex Discrimination Procedural Fairness

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Parties

Mr A J Engel

Applicant

BPP Law Courses Ltd

Respondent

Procedural Posture

Employment Appeal Tribunal / Interlocutory Appeal Against Procedural Orders

Legal Issues

  1. 1 Whether the Employment Tribunal erred in refusing to order disclosure of non-redacted documents containing names of tutors
  2. 2 Whether confidentiality justifies withholding the identity of tutors from the applicant
  3. 3 Whether the appeal raises a question of law under section 21(1) of the Employment Tribunals Act 1996

Ratio Decidendi

The tribunal was entitled to preserve the confidentiality of individual tutors' identities, as disclosure of their names was not necessary for the fair disposal of the applicant's discrimination claims. The appeal did not raise a question of law justifying intervention.

Court Disposition

Appeal dismissed subject to agreed arrangements between parties.

Orders

  • Applicant to be allowed inspection of original comments document (Document B) by 16 April 2003.
  • Original league table documents (Documents A and C) to be produced for inspection by the judge on 16 April 2003 to verify accuracy of redacted versions.