Securicor Custodial Services Ltd v Williams & Anor [2003] UKEAT 0042_02_2901 (29 January 2003)

Securicor Custodial Services Ltd v Williams & Anor [2003] UKEAT 0042_02_2901 (29 January 2003)

The Employment Tribunal erred in law in finding that the dismissal of Miss Williams was race-specific and an act of unlawful race discrimination. There was no sufficient evidence of less favourable treatment or causation on racial grounds, and the dismissal was not inherently race-specific. The appeal is allowed and the finding of unlawful race discrimination is set aside.

Citation
[2003] UKEAT 0042_02_2901
Parties
Appellant: Securicor Management Services Ltd; Respondent: Miss Williams; Second Respondent: Miss Wendy Whitehorn
Jurisdiction
United Kingdom
Judgment Date
29 January 2003
Procedural Posture
Employment Appeal / Appeal From Employment Tribunal Decision
Outcome
Appeal allowed; finding of unlawful race discrimination set aside; final order adjourned pending further application by parties within fourteen days.
Legal Topics
Race Discrimination, Unfair Dismissal, Comparators in Discrimination, Causation in Discrimination, Employment Tribunal Procedure
Employment Law Discrimination Law Race Discrimination Unfair Dismissal Comparators in Discrimination Causation in Discrimination Employment Tribunal Procedure

Case Brief

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Parties

Securicor Management Services Ltd

Appellant

Miss Williams

Respondent

Miss Wendy Whitehorn

Second Respondent

Procedural Posture

Employment Appeal / Appeal From Employment Tribunal Decision

Legal Issues

  1. 1 Whether the dismissal of Miss Williams was an act of unlawful race discrimination under the Race Relations Act 1976
  2. 2 Whether the Employment Tribunal erred in law in finding the dismissal to be race-specific
  3. 3 Whether there was sufficient evidence of less favourable treatment or causation on racial grounds

Ratio Decidendi

The Employment Tribunal erred in law in finding that the dismissal of Miss Williams was race-specific and an act of unlawful race discrimination. There was no sufficient evidence of less favourable treatment or causation on racial grounds, and the dismissal was not inherently race-specific. The appeal is allowed and the finding of unlawful race discrimination is set aside.

Court Disposition

Appeal allowed; finding of unlawful race discrimination set aside; final order adjourned pending further application by parties within fourteen days.

Orders

  • Substitute finding that Securicor did not discriminate unlawfully against Miss Williams on the ground of race.
  • Liberty to apply as to disposal within fourteen days; final order adjourned.