Cases2305069/2023

Claimant v Metropolitan Police Service

25 June 2025Before Employment Judge MortonLondon Southhybrid

Outcome

Claimant fails

Individual claims

Direct Discrimination(religion)failed

The tribunal found that the respondent's decisions in handling the claimant's complaints were taken for reasons related to internal processes and the manner in which the claimant chose to pursue them, not because of her gender-critical beliefs. The claimant restricted what she wanted investigated by refusing to complain against individual officers. The contemporaneous documentary evidence showed no discrimination operating on the minds of decision-makers.

Harassment(religion)failed

The tribunal found that booking Eva Echo to speak and issuing invitations to the Trans Day of Visibility event were not conduct related to the claimant's protected belief, as holders of gender-critical beliefs were not in the organisers' minds. Applying the objective test under s26(4) EqA 2010 and giving proper weight to Article 10 ECHR freedom of expression, the tribunal concluded that the speech and reaction to it at the event did not amount to unlawful harassment. The claimant attended voluntarily without compulsion, was familiar with the divisive nature of the debate, and her broad assumptions about hostility were not justified by the circumstances.

Facts

A trainee detective constable with gender-critical beliefs attended a voluntary online Trans Day of Visibility event organised by the LGBT+ Staff Support Association. She was offended by statements made by external speaker Eva Echo that she considered hostile to gender-critical people, and by the positive reception the talk received from colleagues. She complained through internal processes but was told she would need to name individual officers. She brought tribunal claims of direct discrimination and harassment related to her beliefs.

Decision

The tribunal dismissed both claims. The harassment claim failed because booking Eva Echo and issuing invitations were not conduct related to the claimant's beliefs (gender-critical people were not in the organisers' minds), and objectively, applying Article 10 ECHR principles on freedom of expression, it was not reasonable for the voluntary event to have the harassing effect claimed. The direct discrimination claim failed because the handling of her complaint was dictated by internal processes and her own restrictions on what she wanted investigated, not her beliefs.

Practical note

Article 10 ECHR freedom of expression principles apply when assessing whether offensive speech at a voluntary workplace event amounts to harassment under s26 EqA 2010, particularly where the speech concerns contested matters of public and political interest.

Legal authorities cited

Richmond Pharmacology v Dhaliwal [2009] ICR 724R (Miller) v College of Policing [2021] EWCA Civ 1926Redmond-Bate v DPP [1999] EWHC Admin 733Vajnai v Hungary [2008] ECHR 1910Nailard v Revenue and Customs Commissioners UKEAT/0034/18Forstater v CGD Europe UKEAT/0105/20Higgs v Farmor's School [2023] EWCA Civ 1290

Statutes

Equality Act 2010 s13ECHR Article 10Equality Act 2010 s136Equality Act 2010 s109Equality Act 2010 s26

Case details

Case number
2305069/2023
Decision date
25 June 2025
Hearing type
full merits
Hearing days
8
Classification
contested

Respondent

Sector
emergency services
Represented
Yes
Rep type
barrister

Employment details

Role
Detective Constable (Trainee)
Service
3 years

Claimant representation

Represented
Yes
Rep type
barrister