Cases3313769/2023

Claimant v Open University

16 April 2025Before Employment Judge E DaveyCambridge

Outcome

Claimant fails

Individual claims

Direct Discrimination(age)failed

The tribunal found the claimant's assignment was not extended because of reported concerns about his attitude and behaviour (specifically three incidents in June/July 2023 where he was described as unacceptable, negative, sarcastic and argumentative with duty team managers), not because of his age. The tribunal accepted the respondent's explanation that the claimant was considered difficult to manage. There was no evidential basis to conclude age was a factor — one person offered an extension was older than the claimant, the decision-makers denied age discrimination, and the claimant himself did not raise age as an issue until after early conciliation when he learned he needed a protected characteristic to proceed.

Facts

The claimant was a 43-year-old agency worker on assignment with the Open University as a student recruitment and support advisor from March to September 2023. In June and early July 2023, three duty team managers reported concerns about his attitude, describing him as negative, sarcastic, argumentative and not receptive to feedback. When temporary assignments were reviewed in September 2023, the claimant's was not extended while a younger comparator, Mr Manu (early 20s), was offered an extension despite the claimant having better productivity statistics. The claimant's assignment was terminated with immediate effect after he challenged the decision.

Decision

The tribunal dismissed the age discrimination claim. It found the respondent's reason for not extending the assignment was the claimant's perceived bad attitude and behaviour based on the three reported incidents, not his age. The tribunal noted the lack of documentary evidence and poor management but concluded unfair treatment does not equal discrimination. The claimant failed to establish facts from which discrimination could be inferred, particularly as one person offered an extension was older than him and he only raised age discrimination after ACAS advised him he needed a protected characteristic.

Practical note

Poor management and lack of documentation, even when unfair to an employee, does not create an inference of discrimination without something more connecting the treatment to the protected characteristic — fairness and lawfulness are separate questions.

Legal authorities cited

Hewage v Grampian Health Board [2012] UKSC 37Shamoon v Chief Constable of the Royal Ulster Constabulary [2003] ICR 337Shomer v B and R Residential Lettings Ltd [1992] IRLR 317Igen v Wong [2005] ICR 931Qureshi v Victoria University of Manchester [2001] ICR 863Bahl v The Law Society [2004] IRLR 799Stockton on Tees Borough Council v Aylott [2010] ICR 1278Madarassy v Nomura International Plc [2007] ICR 867

Statutes

Equality Act 2010 s.41Equality Act 2010 s.136Equality Act 2010 s.5Equality Act 2010 s.13Equality Act 2010 s.23

Case details

Case number
3313769/2023
Decision date
16 April 2025
Hearing type
full merits
Hearing days
3
Classification
contested

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Role
Student recruitment and support advisor
Service
6 months

Claimant representation

Represented
No