Cases2303922/2023

Claimant v Parkwood Community Leisure Ltd

5 May 2025Before Employment Judge M AspinallLondon Southin person

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)failed

The tribunal found the claimant did not establish facts from which discrimination could be inferred. Key allegations were not supported: Mr Russell did not introduce himself to white colleague Ms Janetski either; working hours dispute showed consideration of childcare needs; spreadsheet sharing on Google Docs was not substantiated as discriminatory; dismissal was for gross misconduct (unauthorised use of electricity to charge vehicle) with reasonable grounds. The claimant's subjective belief was not supported by objective evidence. Applying Madarassy v Nomura, difference in status and treatment without more was insufficient.

Victimisationfailed

The tribunal found the claimant did a protected act by raising a race discrimination grievance on 26 April 2023. However, suspension on 2 May 2023 and dismissal on 16 June 2023 were not causally linked to the protected act. Suspension followed a specific report from Ms Street about vehicle charging misconduct. Disciplinary process conducted by Mr Cleverly (not implicated in grievance) focused on misconduct allegations. No evidence Mr Russell knew of grievance when suspending. Proximity in time insufficient. On balance of probabilities, actions were because of genuine belief in gross misconduct, not the protected act.

Facts

The claimant, a Black maintenance engineer employed from March 2022 to June 2023 at The Hawth Theatre, raised a race discrimination grievance on 26 April 2023 alleging discriminatory treatment by new management. He was suspended on 2 May 2023 following allegations of unauthorised use of the respondent's electricity to charge his personal electric vehicle, and dismissed for gross misconduct on 16 June 2023. The claimant had insufficient service for unfair dismissal and brought claims of direct race discrimination and victimisation. The respondent's response was struck out for persistent failure to comply with case management orders, though limited participation was permitted.

Decision

The tribunal unanimously dismissed both claims. On race discrimination, the claimant failed to establish less favourable treatment because of race: Mr Russell also did not introduce himself to a white colleague, working hours changes showed consideration of childcare needs, and dismissal was for genuine gross misconduct (unauthorised vehicle charging). On victimisation, the suspension and dismissal were causally linked to the misconduct allegations, not to the protected act of raising a grievance. The claimant's subjective belief was insufficient without objective supporting evidence.

Practical note

A claimant's subjective belief in discrimination, even when coupled with being the only person of that protected characteristic in the workplace, is insufficient without objective evidence showing less favourable treatment was because of the protected characteristic rather than legitimate non-discriminatory reasons.

Legal authorities cited

Madarassy v Nomura International Plc [2007] ICR 867Blockbuster Entertainment Ltd v James [2006] IRLR 630De Keyser v Wilson [2001] IRLR 324Santander UK PLC v Bharaj UKEAT/0075/11Igen v Wong [2005] ICR 931

Statutes

Equality Act 2010 s.123Equality Act 2010 s.27Equality Act 2010 s.13Equality Act 2010 s.136

Case details

Case number
2303922/2023
Decision date
5 May 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
hospitality
Represented
Yes
Rep type
barrister

Employment details

Role
Maintenance Engineer
Service
1 years

Claimant representation

Represented
No