Cases2300498/2023

Claimant v Environment Agency

6 October 2025Before Employment Judge R EvansLondon Southremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)failed

Tribunal found no less favourable treatment because of race. Where facts established (e.g. use of word 'hustling' by Mr Hull, grievance dismissals), tribunal concluded treatment was in no sense whatsoever because of race. Tribunal found respondent's conduct was based on legitimate concerns about claimant's workplace behaviour and relationships with colleagues, not race.

Harassment(race)failed

Tribunal found conduct did not have proscribed purpose or effect, and was not reasonable for it to have had that effect. Critically, claimant conceded during cross-examination that Dr Jennings' conduct did not relate to race, saying 'Dr Jennings has never done anything to me that would be of race.' Burden of proof did not shift.

Victimisationfailed

Protected act was issuing tribunal claim 31 January 2023. Tribunal found no causal link between protected act and alleged detriments (non-renewal of electrical authorisation, required meeting attendance, allegation of code of conduct breach). Decisions were for legitimate operational reasons unconnected to tribunal claim.

Facts

Claimant, a Black African MEICA Advisor employed from 2014 to 2024, brought claims of race discrimination, harassment and victimisation. He had ongoing difficulties with colleagues and managers, resulting in mediations, performance concerns, disciplinary proceedings and grievances. Key allegations included manager Neil Hull describing him as 'hustling' and saying he 'hollers', removal from team organogram, dismissal of grievances, non-renewal of electrical authorisation after bringing tribunal claim, and being required to attend meetings with senior manager Leigh Edlin.

Decision

Tribunal dismissed all claims. Found claimant not a credible witness, accepting he had genuine workplace relationship difficulties for which he bore responsibility. Tribunal found use of word 'hustling' and 'hollers' were not racially motivated. Grievances were properly considered. Non-renewal of electrical authorisation was part of wider policy affecting multiple employees. No causal link established between tribunal claim and alleged victimisation. Claimant conceded during cross-examination that harassment allegation did not relate to race.

Practical note

Even where a claimant raises concerns about potentially racially charged language (e.g. 'hustling', 'hollers'), tribunals will examine context carefully and require cogent evidence of racial motivation; workplace relationship difficulties and performance management processes, even if contested, do not shift burden of proof without more.

Legal authorities cited

Igen v Wong [2005] ICR 931Barton v Investec Securities Ltd [2003] IRLR 332Thomas Sanderson Blinds Ltd v English UKEAT/0316Warby v Winda Group Plc EAT 0434/11Edwards v Unite the Union [2024] EAT 151Efobi v Royal Mail Group Ltd [2021] UKSC 33Madarassy v Nomura International Plc [2007] ICR 867

Statutes

Equality Act 2010 s.26Equality Act 2010 s.27Equality Act 2010 s.39Equality Act 2010 s.13Equality Act 2010 s.123Equality Act 2010 s.136

Case details

Case number
2300498/2023
Decision date
6 October 2025
Hearing type
full merits
Hearing days
8
Classification
contested

Respondent

Name
Environment Agency
Sector
regulator
Represented
Yes
Rep type
barrister

Employment details

Role
MEICA Advisor (mechanical engineer)
Service
10 years

Claimant representation

Represented
No