Sougrin v Haringey Health Authority [1991] UKEAT 586_90_3107 (31 July 1991)

Sougrin v Haringey Health Authority [1991] UKEAT 586_90_3107 (31 July 1991)

The act complained of was the decision not to upgrade the applicant's grade, which was a one-off act with continuing consequences, not a continuing act of discrimination. There was no discriminatory rule or term in the grading criteria. The Industrial Tribunal properly exercised its discretion in refusing to extend the time limit.

Citation
[1991] UKEAT 586_90_3107
Parties
Appellant: Mrs Sougrin; Respondent: Local Health Authority
Jurisdiction
United Kingdom
Judgment Date
31 July 1991
Procedural Posture
Appeal / Judgment on Appeal From Industrial Tribunal
Outcome
Appeal dismissed
Legal Topics
Race Discrimination, Unfair Grading, Limitation Period, Continuing Act Doctrine, Extension of Time
Employment Law Discrimination Law Race Discrimination Unfair Grading Limitation Period Continuing Act Doctrine Extension of Time

Case Brief

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Parties

Mrs Sougrin

Appellant

Local Health Authority

Respondent

Procedural Posture

Appeal / Judgment on Appeal From Industrial Tribunal

Legal Issues

  1. 1 Whether the claim for unfair grading on grounds of race was presented within the statutory time limit
  2. 2 Whether the continued payment of lower wages constituted a 'continuing act' of discrimination under the Race Relations Act 1976
  3. 3 Whether the Industrial Tribunal properly exercised its discretion in refusing to extend the time limit

Ratio Decidendi

The act complained of was the decision not to upgrade the applicant's grade, which was a one-off act with continuing consequences, not a continuing act of discrimination. There was no discriminatory rule or term in the grading criteria. The Industrial Tribunal properly exercised its discretion in refusing to extend the time limit.

Court Disposition

Appeal dismissed