Cases2400757/2024

Claimant v GBT Travel Services UK Ltd

24 September 2025Before Employment Judge DunlopManchesterremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Struck out by Employment Judge Slater on 13 March 2024 because the claimant did not have the required two years of continuous service.

Discrimination Arising from Disability (s.15)(disability)struck out

Dismissed following a preliminary hearing on 10 January 2025 before Employment Judge Butler, who ruled that the claimant was not a disabled person within the meaning of s.6 Equality Act 2010 at the relevant time. The claimant's reconsideration application was refused on 6 March 2025.

Indirect Discrimination(race)failed

The Tribunal found that the PCP of requiring employees to take many telephone calls in English did put non-native English speakers generally at a disadvantage, and put the claimant specifically at a disadvantage. However, the respondent justified the PCP as a proportionate means of achieving the legitimate aim of servicing clients in English. There was no less discriminatory way to achieve this necessary business requirement.

Facts

Miss Nazirova, an Azerbaijani national whose first language was not English, was employed as a Travel Counsellor by GBT Travel Services UK Ltd from January 2023 to February 2024. She struggled with the telephone-based work, particularly on the demanding Goldman Sachs account, for multiple reasons including her limited English fluency, health issues (tinnitus/ENT problems), and stress. She was given extra support and completed her probationary period in September 2023. She resigned in January 2024 following a disciplinary warning (unrelated to her performance) citing unfair treatment and bullying.

Decision

The Tribunal dismissed all claims. The unfair dismissal claim was struck out for lack of qualifying service. The disability discrimination claims were dismissed at an earlier preliminary hearing. The indirect race discrimination claim succeeded on the issues of group disadvantage and individual disadvantage (non-native English speakers being disadvantaged by requirement to take many calls in English) but failed because the respondent justified the PCP as a proportionate means of achieving the legitimate aim of servicing clients in English, with no less discriminatory alternative available.

Practical note

Language requirements in customer-facing telephone roles may constitute indirect race discrimination against non-native speakers, but will be justified where fluent English communication is genuinely necessary for the job and no reasonable alternative exists.

Legal authorities cited

Kilraine v London Borough of Wandsworth [2018] ICR 1850Chief Constable of West Yorkshire Police v Homer [2012] ICR 704Dziedziak v Future Electronics Ltd EAT 0271/11University of Manchester v Jones [1993] ICR 474Essop v Home Office (UK Border Agency) [2017] UKSC 27Andreou v Lord Chancellor's Department 2002 IRLR 728Phelan v Richardson Rogers Ltd [2021] ICR 1164

Statutes

Equality Act 2010 s.6Equality Act 2010 s.19

Case details

Case number
2400757/2024
Decision date
24 September 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
solicitor

Employment details

Role
Travel Counsellor
Service
1 years

Claimant representation

Represented
No