Cases3302208/2024

Claimant v Sensient Flavors LLC

18 June 2025Before Employment Judge AlliottWatfordin person

Outcome

Other

Individual claims

Unfair Dismissalnot determined

This is a preliminary hearing dealing with protected belief, strike-out applications and case management. The substantive claims including unfair dismissal have not yet been determined.

Constructive Dismissalnot determined

Alternative basis for claiming unfair dismissal. Not yet determined at this preliminary hearing stage.

Wrongful Dismissalnot determined

Breach of contract claim not yet determined at this preliminary hearing stage.

Direct Discrimination(religion)not determined

The tribunal determined that the claimant's beliefs (regarding white middle-aged male privilege and female disadvantage) do constitute protected philosophical beliefs under s.10 Equality Act 2010, applying Grainger criteria. The substantive discrimination claim has not yet been determined.

Direct Discrimination(sex)not determined

Alternative basis for direct discrimination claim. Not yet determined at this preliminary hearing stage.

Harassment(religion)not determined

Harassment claim based on protected philosophical belief. Not yet determined at this preliminary hearing stage.

Harassment(sex)not determined

Alternative basis for harassment claim. Not yet determined at this preliminary hearing stage.

Victimisationnot determined

Victimisation claim not yet determined at this preliminary hearing stage.

Facts

The claimant was employed as a Senior HR Manager from July 2014. Her employment ended in disputed circumstances in October/November 2023, with the claimant alleging dismissal and the respondent contending resignation. The claimant brought claims including unfair/constructive dismissal, wrongful dismissal, and discrimination based on philosophical belief and sex. At a preliminary hearing the tribunal had to determine whether the claimant's stated beliefs (that white middle-aged men have unconscious privilege and that women remain disadvantaged) constituted protected philosophical beliefs under s.10 Equality Act 2010.

Decision

The tribunal held that the claimant's two beliefs did constitute protected philosophical beliefs under the Equality Act 2010, applying the Grainger criteria. The tribunal found the beliefs crossed the threshold from widely-held opinions into philosophical beliefs that guide the claimant's behaviour. One allegation was struck out (termination of employment) but otherwise the respondent's strike-out and deposit order applications were dismissed. The claimant's costs application was also dismissed.

Practical note

Beliefs about systemic gender inequality and male privilege in the workplace can constitute protected philosophical beliefs under the Equality Act 2010 if they go beyond opinions to become guiding principles that affect how a person lives their life, even if narrowly defined and potentially offensive to some.

Legal authorities cited

McClintock v Department of Constitutional Affairs [2008] IRLR 29Mackereth v DWP [2022] ICR 1609Grainger Plc v Nicholson [2010] ICR 360Gray v Mulberry Co (Design) Ltd [2020] ICR 715Forstater v CGD Europe [2022] ICR 1

Statutes

ERA 1996Equality Act 2010 s.10

Case details

Case number
3302208/2024
Decision date
18 June 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
manufacturing
Represented
Yes
Rep type
barrister

Employment details

Role
Senior Human Resources Manager

Claimant representation

Represented
Yes
Rep type
barrister