Cases6000841/2024

Claimant v A Kahn Design Limited

20 May 2025Before Employment Judge ShulmanLeedsin person

Outcome

Partly successful

Individual claims

Victimisationstruck out

The tribunal struck out all 71 alleged detriments of victimisation. The protected act relied upon was an email dated 22 March 2020 sent to a colleague supporting that colleague's grievance, but this email was unclear and did not relate to any contravention of the Equality Act 2010. Many detriments occurred before the protected act, many were not detriments at all, many were unconnected to the protected act, and the tribunal found the claim had no reasonable prospect of success.

Failure to Make Reasonable Adjustments(disability)not determined

This claim remains live but was not determined at this preliminary hearing which dealt with without prejudice correspondence and the victimisation strike-out application.

Harassment(disability)not determined

This claim remains live but was not determined at this preliminary hearing.

Unlawful Deduction from Wagesnot determined

This claim remains live but was not determined at this preliminary hearing.

Breach of Contractnot determined

This claim remains live but was not determined at this preliminary hearing.

Constructive Dismissalnot determined

This claim remains live but was not determined at this preliminary hearing.

Holiday Paynot determined

This claim remains live but was not determined at this preliminary hearing.

Facts

Mr White, employed by A Kahn Design Limited, brought multiple claims including victimisation based on 71 alleged detriments. He claimed the protected act was an email dated 22 March 2020 sent to a colleague supporting that colleague's grievance. Settlement negotiations occurred between January and June 2022 with offers and counter-offers exchanged, but no settlement was reached. The employment ended on 30 April 2024. This preliminary hearing considered whether certain correspondence was without prejudice and whether the victimisation claims should be struck out.

Decision

The tribunal ruled that correspondence between pages 188-207 of the bundle constituted without prejudice communications and was inadmissible at the final hearing. Section 111A ERA was found not to apply as negotiations ended nearly two years before termination. The tribunal struck out all victimisation claims, finding the protected act was unclear, did not relate to any EqA contravention, and the allegations had no reasonable prospect of success.

Practical note

A protected act for victimisation must clearly allege a contravention of the Equality Act; supporting a colleague's general grievance without any equality law element is insufficient.

Legal authorities cited

Statutes

ERA 1996 s.111AEqA 2010 s.27

Case details

Case number
6000841/2024
Decision date
20 May 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
lay rep

Claimant representation

Represented
Yes
Rep type
barrister