Cases8001793/2024

Claimant v Secretary of State for Work and Pensions

8 July 2025Before Employment Judge P O'DonnellScotlandremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(age)dismissed on withdrawal

Claim 2 relating to comparison with staff on SEO Grades in the same age group as claimant was withdrawn by the claimant at the hearing and dismissed under Rule 51.

Direct Discrimination(age)struck out

Claim 1 relating to the difference in pay rises between 'Employee Deal' terms (5.5%) and 'legacy terms' (4.5%) was struck out as having no reasonable prospects of success. The tribunal found the difference in treatment was due to different contractual terms, not age. All staff on legacy terms could opt to move to Employee Deal terms regardless of age, and the claimant chose not to do so.

Facts

The claimant, aged 40-65, was employed on 'legacy terms' (pre-2016 contractual terms) and received a 4.5% pay rise. He brought age discrimination claims comparing himself to younger staff on 'Employee Deal' terms (post-2016) who received 5.5% pay rises. All staff on legacy terms, regardless of age, could opt to move to Employee Deal terms but the claimant chose not to do so. The respondent applied to strike out the claim.

Decision

The tribunal struck out the age discrimination claim as having no reasonable prospects of success. The difference in pay rises was due to different contractual terms, not age. Since all employees regardless of age could move to Employee Deal terms and the claimant chose not to, the treatment was not because of age. One claim was also withdrawn by the claimant.

Practical note

A difference in treatment based on contractual terms that employees can freely choose, regardless of their protected characteristic, will not establish direct discrimination even if there is a correlation between the characteristic and the terms.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867Anyanwu v South Bank Student Union [2001] ICR 391Mechkarov v Citibank NA [2016] ICR 1121Hemdan v Ishmail [2017] IRLR 228Van Rensburg v Royal Borough of Kingston-upon-Thames UKEAT/0095/07Bahl v The Law Society [2004] IRLR 799Igen v Wong [2005] ICR 931Hewage v Grampian Health Board [2012] UKSC 37HM Prison Service v Dolby [2003] IRLR 694Hasan v Tesco Stores Ltd UKEAT/0098/16Mbuisa v Cygnet Healthcare Ltd EAT 0119/18

Statutes

Equality Act 2010 s.13Equality Act 2010 s.23

Case details

Case number
8001793/2024
Decision date
8 July 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
central government
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No