Cases3302394/2023

Claimant v London Borough of Harrow

19 September 2025Before Employment Judge WyethWatfordin person

Outcome

Other

Individual claims

Direct Discrimination(race)not determined

Respondent's application to strike out race discrimination complaints under r38(1)(a) was refused. The tribunal found the matter finely balanced but decided not to make a deposit order, primarily to avoid trespassing on a previous decision by EJ Dick, and determined the claims should proceed to trial to be determined on evidence.

Direct Discrimination(race)not determined

Allegations relate to claimant's East African Indian ethnicity. The tribunal expressed doubts about prospects of success, noting the claimant stated one comparator (KP) was unaware of her ethnicity until January 2021 and that she did not believe another comparator (BD) treated her differently because of this ethnicity. However, the claim was allowed to proceed to trial.

Harassment(race)not determined

Alternative claim to direct discrimination. While the tribunal had doubts about the direct discrimination claims, it found that harassment claims were not necessarily precluded and should be determined at trial on the basis of evidence.

Facts

The claimant, representing herself, brought race discrimination claims against Harrow Council. The respondent applied to strike out the claim for non-pursuit due to the claimant's failure to comply with tribunal orders, which she attributed to health difficulties. The respondent also applied to strike out or order a deposit on race discrimination claims, arguing the claimant had vacillated on her protected characteristic (initially British Asian, later East African Indian) and that her purported ethnicity could not be a recognised ethnic group. Key witnesses mentioned include KP, BD, and RS.

Decision

Employment Judge Wyeth refused both strike-out applications. On the non-pursuit application, the judge found the delay was not inordinate and inexcusable to the extent required, and that key witnesses remained available so a fair hearing was possible. On the race discrimination application, the judge declined to make a deposit order, primarily to avoid trespassing on a previous decision by EJ Dick who had already considered similar arguments, and determined the matter should proceed to trial.

Practical note

A tribunal will be reluctant to strike out claims or order deposits at a preliminary hearing where previous case management decisions have addressed similar issues, and where a fair trial remains possible despite procedural delays, particularly when the claimant is unrepresented and has health difficulties.

Legal authorities cited

Evans and anor v Commissioner of Police of the Metropolis [1993] ICR 151, CAMandla v Dowell Lee [1983] ICR 385Birkett v James [1978] AC 297, HL

Statutes

Equality Act 2010ET Rules 2024 r40ET Rules 2024 r38(1)(a)ET Rules 2024 r38(1)(d)

Case details

Case number
3302394/2023
Decision date
19 September 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
local government
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No