Cases8001626/2024

Claimant v Indigo Pipelines Ltd

20 May 2025Before Employment Judge R MackayScotlandin person

Outcome

Claimant fails

Individual claims

Breach of Contractfailed

The tribunal found no binding contract was formed. Although Ms Scott offered £32,000 verbally, the claimant did not accept it, both parties anticipated a written contract would be required, there was no agreement on essential terms beyond salary, and no intention to be bound immediately. Language used by claimant referred to 'offer' and 'negotiations' not concluded contract.

Victimisation(race)failed

Three alleged protected acts were examined. First (conversation with Ms Kinsman 15 & 29 August): tribunal found no race discrimination allegations were made, only complaints about salary unfairness. Second (conversation with Ms Thompson 29 August): claimant conceded no mention of race or discrimination. Third (conversation with Ms Critchley 30 August): this was a protected act as claimant explicitly mentioned being 'a woman of colour' and discrimination. However, detriments relied upon either predated this act or had no causal link to it. Claim failed on causation.

Facts

Claimant was engaged as agency worker by respondent from March 2024 as administrator, later trained as asset engagement officer. Verbal discussions took place about permanent role at £32,000 salary which claimant understood was offered but then reduced to £27,500. Following Town Hall meeting on 29 August 2024, claimant complained to HR about salary reduction and contract handling. Her engagement was terminated on 30 August 2024 due to reduced workload from new systems. On call with HR adviser Ms Critchley later that day, claimant mentioned being 'woman of colour' and discrimination in context of equal pay comparison.

Decision

Both claims dismissed. No binding employment contract formed as no acceptance of verbal offer, both parties anticipated written contract required, insufficient agreement on essential terms beyond salary, and no intention to be immediately bound. Victimisation claim failed as first two alleged protected acts did not constitute sufficiently clear allegations of race discrimination, and detriments relating to third protected act (which was established) either predated it or had no causal link to it.

Practical note

A verbal salary discussion does not create a binding employment contract where parties expect a written document to follow and have not agreed essential terms, and complaints about unfair treatment without reference to protected characteristics cannot constitute protected acts under s.27 Equality Act even if the complainant is from an ethnic minority.

Legal authorities cited

Hendricks v Metropolitan Police Commissioner [2003] ICR 530Durrani v London Borough of Ealing UKEAT/0454/12Chalmers v Airpoint Ltd UKEATS/0013/19Chief Constable of Greater Manchester Police v Bailey [2017] EWCA Civ 425Peninsula Business Services Ltd v Baker UKEAT/0241/16Shamoon v Chief Constable of the Royal Ulster Constabulary [2003] ICR 337Nagarajan v London Regional Transport [2000] 1 AC 501WS Karoulias SA v Drambuie Liqueur Co Ltd (No 2) 2005 SLT 813Avintair Ltd v Ryder Airline Services Ltd 1994 SC 270Donald McArthy Trading Pte Ltd v Ireland Alloys Ltd [2020]Morgan Utilities Ltd v Scottish Water Solutions Ltd [2011] CSOH 112Beneviste v Kingston University UKEAT/0393/05

Statutes

Equality Act 2010 s.41Equality Act 2010 s.27

Case details

Case number
8001626/2024
Decision date
20 May 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
energy
Represented
Yes
Rep type
barrister

Employment details

Role
Administrator / Asset Engagement Officer
Service
5 months

Claimant representation

Represented
No