Cases2206280/2023

Claimant v Metropolitan Police Service

19 March 2025Before Employment Judge WebsterLondon Centralin person

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)failed

Tribunal found that many of the alleged incidents did not occur as described. Where incidents did occur, the Claimant failed to establish any evidence that treatment was because of race or that he was treated less favourably than a comparator. The Respondent provided non-discriminatory reasons for all treatment, primarily the Claimant's performance and conduct issues.

Harassment(race)failed

The single incident relied upon (PS Kovler mimicking the Claimant's African accent on 23 December 2022) was found by the Tribunal not to have occurred.

Constructive Dismissalfailed

The Claimant lacked jurisdiction to bring an unfair dismissal claim as a police officer office holder under s.200 ERA 1996. Even if jurisdiction existed, the Tribunal found no repudiatory breach of contract and that the Claimant resigned to avoid a disciplinary process regarding unauthorised Uber driving, not in response to any breach by the Respondent.

Detrimentfailed

The Claimant's claim under s.10 Employment Relations Act 1999 for denial of the right to be accompanied failed. The meetings on 18 October and 29 November 2023 were not disciplinary or grievance hearings to which the right applied. The Claimant also lacked jurisdiction as a police officer office holder who is not a 'worker' under the Act.

Facts

The Claimant, a Black African Police Constable with the Metropolitan Police from February 2020 to November 2023, brought claims of race discrimination, harassment, constructive unfair dismissal and denial of the right to be accompanied. The claims arose from performance management incidents in December 2022 following errors in case handling, a traffic accident in October 2023 where he was driving for Uber without authorisation, and subsequent fact-finding meetings. The Claimant resigned on 24 October 2023, giving notice to 29 November 2023, during an investigation into unauthorised external business interests.

Decision

The Tribunal dismissed all claims. Key factual allegations (including accent mimicking and deliberate sabotage) were found not to have occurred. Where incidents did occur, the Tribunal found they were due to the Claimant's performance and conduct issues, not race. The Claimant lacked jurisdiction for unfair dismissal and right to be accompanied claims as a police officer office holder. The Tribunal was critical of the Claimant's credibility, noting he introduced serious new allegations during the hearing without evidence and failed to provide comparative evidence to support discrimination claims.

Practical note

Police officers as office holders have limited employment rights and cannot bring ordinary unfair dismissal claims; even where institutional discrimination is a recognised issue within an organisation, individual claimants must provide specific evidence linking their treatment to a protected characteristic rather than relying on negative experiences alone.

Legal authorities cited

Nagarajan v London Regional Transport [2000] 1 AC 501Redbridge LBC v Dhinsa [2014] ICR 834Commissioner of Police of the Metropolis v Lowrey-Nesbitt [1999] ICR 401Igen Ltd v Wong 2005 ICR 931Madarassy v Nomura International plc 2007 ICR 867Hewage v Grampian Health Board 2012 ICR 1054Western Excavating (ECC) Ltd v Sharp 1978 ICR 221Bournemouth University Higher Education Corporation v Buckland 2010 ICR 908Land Registry v Grant [2011] ICR 1390Stockton on Tees Borough Council v Aylott 2010 ICR 1278Malik v Bank of Credit and Commerce International [1998] AC 20

Statutes

Equality Act 2010 s.26Equality Act 2010 s.136Employment Relations Act 1999 s.10Employment Rights Act 1996 s.200Employment Rights Act 1996 s.95(1)(c)Employment Rights Act 1996 s.230Equality Act 2010 s.13

Case details

Case number
2206280/2023
Decision date
19 March 2025
Hearing type
full merits
Hearing days
7
Classification
contested

Respondent

Sector
emergency services
Represented
Yes
Rep type
barrister

Employment details

Role
Police Constable
Service
4 years

Claimant representation

Represented
No