Hall v Chief Constable Of West Yorkshire Police (Disability Discrimination : Section 15) [2015] UKEAT 0057_15_0707 (07 July 2015)

Hall v Chief Constable Of West Yorkshire Police (Disability Discrimination : Section 15) [2015] UKEAT 0057_15_0707 (07 July 2015)

The Employment Tribunal erred in law by imposing too stringent a causal link and focusing on motivation rather than the reason for treatment; section 15 requires only that the unfavourable treatment was because of something arising in consequence of the disability, which was established on the facts.

Source-derived case information.

Citation
[2015] UKEAT 0057_15_0707
Parties
Claimant: Miss Hall; Respondent: West Yorkshire Police
Jurisdiction
United Kingdom
Judgment Date
07 July 2015
Procedural Posture
Employment Appeal / Appeal Against Reserved Judgment of Employment Tribunal
Outcome
Appeal allowed; Employment Tribunal decision on disability discrimination reversed.
Legal Topics
Disability Discrimination, Section 15 Equality Act 2010, Unfair Dismissal, Causation in Discrimination
Employment Law Equality Law Disability Discrimination Section 15 Equality Act 2010 Unfair Dismissal Causation in Discrimination

Source-derived case record

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 4 Authorities cited 22 Party arguments 2 Amounts and remedies 2
Sign in to unlock

Parties

Miss Hall

Claimant

West Yorkshire Police

Respondent

Procedural Posture

Employment Appeal / Appeal Against Reserved Judgment of Employment Tribunal

Legal Issues

  1. 1 Whether the Employment Tribunal erred in its interpretation of section 15 of the Equality Act 2010 regarding causation in disability discrimination
  2. 2 Whether the Claimant was subjected to unfavourable treatment because of something arising in consequence of her disability
  3. 3 Whether the treatment was a proportionate means of achieving a legitimate aim

Ratio Decidendi

The Employment Tribunal erred in law by imposing too stringent a causal link and focusing on motivation rather than the reason for treatment; section 15 requires only that the unfavourable treatment was because of something arising in consequence of the disability, which was established on the facts.

Court Disposition

Appeal allowed; Employment Tribunal decision on disability discrimination reversed.

Orders

  • Claim for disability discrimination under section 15 Equality Act 2010 succeeds.
  • Employment Tribunal to reconsider remedy if necessary.