Cases2200026/2022

Claimant v Embassy of the Sultanate of Oman in London

3 July 2025Before Employment Judge L BrownLondon Central

Outcome

Other

Individual claims

Direct Discrimination(sex)not determined

This preliminary hearing determined only the question of state immunity. The claim was brought in the first claim form (2200026/2022) alleging direct sex discrimination. The tribunal found the claim was not barred by state immunity and could proceed.

Harassment(sex)not determined

This preliminary hearing determined only the question of state immunity. The claim was brought in the first claim form alleging sex harassment. The tribunal found the claim was not barred by state immunity and could proceed.

Direct Discrimination(race)not determined

This preliminary hearing determined only the question of state immunity. The claimant relied on being British of Iranian ethnic origin and not being Omani. The tribunal found the claim was not barred by state immunity and could proceed.

Victimisationnot determined

Victimisation claims were brought in both claim forms. The claimant alleged she was victimised for complaining of sexual harassment and racial discrimination, and that her employment was terminated 10 days after bringing the first claim. The tribunal found the claims were not barred by state immunity and could proceed.

Unfair Dismissalnot determined

Brought in the second claim form (2205484/2022) alleging the dismissal was unfair and amounted to victimisation. The tribunal found the claim was not barred by state immunity and could proceed.

Holiday Paynot determined

Brought in the second claim form alleging failure to pay holiday pay. The tribunal found the claim was not barred by state immunity and could proceed.

Facts

The claimant was employed from 2009 as Senior Academic Advisor at the Omani Embassy's Cultural Attaché Office, which dealt with Omani students studying in the UK. Her role was purely administrative: updating databases, answering student queries, forwarding requests to the Ministry of Higher Education, and sending documents to universities. She brought claims of sex and race discrimination, harassment, victimisation, unfair dismissal and unpaid holiday pay. The respondent argued state immunity applied because her employment and dismissal were exercises of sovereign authority.

Decision

The tribunal held that the claimant's claims were not barred by state immunity. Her administrative functions were not sufficiently close to the governmental functions of the mission to constitute sovereign acts—they were ancillary clerical tasks such as any private person might perform. Her dismissal was not an act of sovereign authority. In any event, the respondent had submitted to the tribunal's jurisdiction by filing a substantive defence and case management agenda going beyond merely asserting immunity.

Practical note

Embassy administrative staff performing purely clerical support functions are not protected by state immunity even when supporting a department carrying out governmental functions, because their work does not involve personal participation in diplomatic or political operations.

Legal authorities cited

Royal Embassy of Saudi Arabia v Al Hayali [2023] EAT 149Sengupta v Republic of India [1983] ICR 221Governor of Pitcairn and Associated Islands v Sutton (1994) 104 ILR 508Holland v Lampen-Wolfe [2000] 1 WLR 1573Kuwait Airways Corporation v Iraqi Airways Company and Republic of Iraq [1995] 1 Lloyd's Rep 25The Royal Embassy of Saudi Arabia (Cultural Bureau) v Costantine [2025] UKSC 9Benkharbouche v Secretary of State for Foreign and Commonwealth Affairs [2018] IRLR 123

Statutes

State Immunity Act 1978 s2State Immunity Act 1978 s1Vienna Convention on Diplomatic Relations Article 3State Immunity Act 1978 (Remedial) Order 2023State Immunity Act 1978 s16State Immunity Act 1978 s4

Case details

Case number
2200026/2022
Decision date
3 July 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
lay rep

Employment details

Role
Senior Academic Advisor

Claimant representation

Represented
Yes
Rep type
barrister