Cases8000247/2025

Claimant v Anyiso SCIO

2 September 2025Before Employment Judge D HoeyScotlandin person

Outcome

Claimant fails

Individual claims

Automatic Unfair Dismissalfailed

The tribunal found the sole reason for dismissal was the claimant's failure to follow instructions, breach of confidentiality, and failure to follow company policy. The protected disclosures were not the sole or principal reason for dismissal.

Direct Discrimination(race)failed

The tribunal found no less favourable treatment on grounds of race. Any employee in the claimant's circumstances would have been treated in the same way. Race was in no sense whatsoever a reason for the treatment.

Harassment(race)failed

None of the alleged unwanted acts were found to be related to the protected characteristic of race. The tribunal found that even where conduct was established, it was not related to race and did not have the proscribed effects.

Whistleblowingfailed

The tribunal found no detriments suffered by the claimant because of protected disclosures. The manager had not read the health and safety disclosure before deciding to dismiss, and other treatment was solely due to perceived performance failures, not the disclosures.

Indirect Discrimination(race)withdrawn

Withdrawn by claimant at the hearing.

Facts

The claimant, an Arabic community development officer, worked for a charity supporting ethnic minority women. Her relationship with her manager Ms Ezechi deteriorated over perceived performance issues, including failing to follow instructions, not logging donated items, and breaching confidentiality by asking service users about hot water temperature on WhatsApp. Ms Ezechi dismissed the claimant on 23 December 2024 after seven months' employment, citing inability to follow instructions, unrecorded donated items, and breach of confidentiality. The claimant had raised concerns about underpayment and health and safety issues shortly before dismissal.

Decision

The tribunal dismissed all claims. It found the claimant was not treated less favourably on grounds of race — any employee in similar circumstances would have been treated the same way. The manager's treatment stemmed from frustration at perceived performance failures, not race. The whistleblowing claims failed because the manager had not read the health and safety disclosure before deciding to dismiss, and other treatment was unrelated to the disclosures. The dismissal was not automatically unfair as the protected disclosures were not the sole or principal reason.

Practical note

Poor management style and a deteriorating working relationship do not amount to discrimination or whistleblowing detriment unless the protected characteristic or disclosure materially influenced the treatment — subjective perception of unfairness is insufficient without objective evidence of unlawful motivation.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867GMB v Henderson [2017] IRLR 340Bakkali v Greater Manchester [2018] IRLR 906Lindsay v LSE [2014] IRLR 218Land Registry v Grant [2011] IRLR 748Fecitt v Manchester [2012] ICR 372Royal Mail Group Ltd v Jhuti [2019] UKSC 55Kuzel v Roche Products Ltd [2008] ICR 799Abernethy v Mott, Hay and Anderson [1974] ICR 323The Co-Operative Group Ltd v Baddeley [2014] EWCA Civ 658Nicol v World Travel and Tourism Council [2024] EAT 42William v Lewisham and Greenwich NHS Trust [2024] EAT 58Malik v Centros Securities EAT/0100/17Nagarajan v London Regional Transport [2000] 1 AC 501Anya v University of Oxford [2001] ICR 847

Statutes

Employment Rights Act 1996 s.103AEquality Act 2010 s.13Employment Rights Act 1996 s.43BEquality Act 2010 s.26Employment Rights Act 1996 s.43AEquality Act 2010 s.23Employment Rights Act 1996 s.43CEmployment Rights Act 1996 s.43FEmployment Rights Act 1996 s.47BEmployment Rights Act 1996 s.48(2)

Case details

Case number
8000247/2025
Decision date
2 September 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
charity
Represented
Yes
Rep type
lay rep

Employment details

Role
Community Development Officer
Service
7 months

Claimant representation

Represented
Yes
Rep type
lay rep