Cases2201955/2024

Claimant v Imperial College of Science Technology and Medicine

1 August 2025Before Employment Judge DavidsonLondon Central

Outcome

Partly successful

Individual claims

Direct Discrimination(race)struck out

Claim relating to racial slur by Professor Tyrer (not employed by the respondent) struck out on the basis that there is no reasonable prospect of showing the first respondent is liable or that the claimant was treated less favourably.

Direct Discrimination(race)struck out

Claim against fourth respondent (Professor Titirici) relating to single email on 20 February 2023 struck out as presented nine months out of time with no reasonable prospect of being part of course of conduct or time extension on just and equitable basis.

Direct Discrimination(race)struck out

Claim against sixth respondent (Hannah Bannister) relating to single comment on 7 September 2022 struck out as presented 15 months out of time with no reasonable prospect of being part of course of conduct or time extension on just and equitable basis.

Detriment(race)struck out

Detriment 2.1.2 (requiring claimant to apply for role) struck out as claimant conceded she did not believe treatment was motivated by race.

Detriment(race)struck out

Detriment 2.1.12 (instruction to allow witnesses at disciplinary hearing) struck out as no prospect of showing this amounts to actionable claim or detriment.

Detriment(race)struck out

Detriment 2.1.13 (organising leaving card and collection when unwelcome) struck out as no prospect of showing this amounts to less favourable treatment.

Detriment(race)struck out

Detriment 2.1.15 (removal of annual leave entry from team calendar) struck out as no prospect of showing this amounts to less favourable treatment or harassment.

Detriment(race)not determined

Multiple other detriment claims relating to handling of data subject access request, recording of conversations, and conduct of meetings were allowed to proceed as they can only be determined by hearing evidence.

Harassment(race)not determined

Harassment claims remain valid where not specifically struck out and can only be determined by hearing evidence.

Facts

The claimant, an HR employee at Imperial College, brought race discrimination claims against the College and six individual respondents arising from multiple alleged detriments and acts of harassment. The claim was initially presented late in January 2024 following an earlier defective filing in September 2023. The respondents applied to strike out various allegations as having no reasonable prospect of success, including claims against two individuals based on single isolated incidents.

Decision

The tribunal struck out several allegations including the claim relating to a comment by Professor Tyrer (not employed by the respondent), claims against the fourth and sixth respondents based on isolated incidents presented 9 and 15 months out of time with no reasonable prospect of time extension, and four specific detriment allegations that did not meet the threshold or where the claimant conceded race was not a factor. The bulk of the claimant's claims were allowed to proceed.

Practical note

Isolated incidents by individual respondents presented significantly out of time will be struck out where there is no reasonable prospect of establishing continuing conduct and the balance of prejudice weighs heavily against extending time, even in discrimination cases.

Legal authorities cited

Ezsias v North Glamorgan NHS Trust [2007] EWCA Civ 330Caterham School Ltd v Rose UKEAT/0149/19Worcestershire Health and Care NHS Trust v Angela Allen [2024] EAT 40

Statutes

Equality Act 2010 s.13Employment Tribunals (Constitution and Rules of Procedure) Regulations 2024 Rule 38(1)(a)Equality Act 2010 s.39

Case details

Case number
2201955/2024
Decision date
1 August 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Role
HR

Claimant representation

Represented
No