Cases4100548/2024

Claimant v Stirling Council

14 April 2025Before Employment Judge A KempScotlandin person

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)failed

The tribunal found no evidence that race played any substantial part in the decisions not to appoint the claimant. For the first post, additional ASN Outreach support made the role unnecessary—anyone booked would have been cancelled. For the second post, the claimant's application did not meet the essential criteria relating to experience with challenging behaviour, whereas the four shortlisted candidates did. Ms McGonigle was unaware of the claimant's beliefs and race played no part consciously or subconsciously in her assessment.

Direct Discrimination(religion)failed

The tribunal accepted that the respondent's decision-makers were not aware of the claimant's belief (opposition to the Chinese Communist Party). As such, her belief could not have influenced the decisions either consciously or subconsciously. The claimant's genuine suspicion that the Confucius Institute influenced the decisions was not supported by any primary fact evidence.

Facts

The claimant, a Chinese national opposed to the Chinese Communist Party, applied for two Support for Learning Assistant posts with Stirling Council. She was initially booked for the first post (four SLA roles at Bannockburn High School) in August 2023 but the booking was cancelled because additional ASN Outreach support was provided, making all four roles unnecessary. She applied for a second post at Stirling High School in September 2023 but was not shortlisted for interview. Fourteen applicants applied; four were shortlisted based on meeting the essential criteria of experience with challenging pupil behaviour. The claimant's application did not demonstrate this experience. She believed the Confucius Institute influenced both decisions because of her political beliefs and race.

Decision

The tribunal dismissed both discrimination claims. It found no evidence that the claimant's race or belief played any part in the decisions. For the first post, the cancellation was due to provision of central ASN Outreach support, which would have affected any applicant. For the second post, the claimant's application did not meet the essential criteria, whereas successful applicants did. The decision-makers were unaware of the claimant's political beliefs. There was no primary fact evidence supporting the claimant's suspicion of Confucius Institute involvement.

Practical note

Genuine suspicion of discrimination, even when rooted in a claimant's difficult historical experiences, cannot substitute for primary fact evidence showing a causal link between a protected characteristic and less favourable treatment.

Legal authorities cited

Nagarajan v London Regional Transport [2000] 1 AC 501JP Morgan Europe Limited v Chweidan [2011] IRLR 673Laing v Manchester City Council [2006] IRLR 748The Law Society v Bahl [2003] IRLR 640The Law Society v Bahl [2004] IRLR 799Ayodele v Citylink Ltd [2018] ICR 748Geller v Yeshurun Hebrew Congregation [2016] ICR 1028Anya v University of Oxford [2001] ICR 847Glasgow City Council v Zafar [1998] ICR 120Shamoon v Chief Constable of the Royal Ulster Constabulary [2003] ICR 337Igen v Wong [2005] ICR 931Madarassy v Nomura International Plc [2007] ICR 867Efobi v Royal Mail Group Ltd [2021] UKSC 33Hewage v Grampian Health Board [2012] UKSC 37Amnesty International v Ahmed [2009] IRLR 884

Statutes

Equality Act 2010 s.4Equality Act 2010 s.9Equality Act 2010 s.10Equality Act 2010 s.13Equality Act 2010 s.23Equality Act 2010 s.39Equality Act 2010 s.136

Case details

Case number
4100548/2024
Decision date
14 April 2025
Hearing type
full merits
Hearing days
2
Classification
contested

Respondent

Name
Stirling Council
Sector
local government
Represented
Yes
Rep type
solicitor

Employment details

Role
Support for Learning Assistant

Claimant representation

Represented
Yes
Rep type
solicitor