Patel v City Of Bradford Metropolitan Council [1993] UKEAT 543_91_0707 (7 July 1993)

Patel v City Of Bradford Metropolitan Council [1993] UKEAT 543_91_0707 (7 July 1993)

The Industrial Tribunal was entitled to find, on the evidence, that Mrs Patel was not treated less favourably on racial grounds, despite flaws in the selection process and failure to follow codes of practice. The Tribunal did not err in law in its approach or application of the Race Relations Act 1976.

Citation
[1993] UKEAT 543_91_0707
Parties
Appellant: Mrs Ramila Patel; Respondent: Bradford Metropolitan District Council
Jurisdiction
United Kingdom
Judgment Date
07 July 1993
Procedural Posture
Employment Appeal / Appeal From Industrial Tribunal Decision
Outcome
Appeal dismissed
Legal Topics
Racial Discrimination, Recruitment and Selection, Burden of Proof, Codes of Practice
Employment Law Equality Law Racial Discrimination Recruitment and Selection Burden of Proof Codes of Practice

Case Brief

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Parties

Mrs Ramila Patel

Appellant

Bradford Metropolitan District Council

Respondent

Procedural Posture

Employment Appeal / Appeal From Industrial Tribunal Decision

Legal Issues

  1. 1 Whether the selection process for trainee co-ordinator posts involved unlawful racial discrimination against Mrs Patel
  2. 2 Whether the Industrial Tribunal applied the correct statutory provision under the Race Relations Act 1976
  3. 3 Whether failure to follow codes of practice or to seek hard evidence of capability amounted to discrimination

Ratio Decidendi

The Industrial Tribunal was entitled to find, on the evidence, that Mrs Patel was not treated less favourably on racial grounds, despite flaws in the selection process and failure to follow codes of practice. The Tribunal did not err in law in its approach or application of the Race Relations Act 1976.

Court Disposition

Appeal dismissed