Cases1302171/2022

Claimant v University of Birmingham

29 January 2025Before Employment Judge CampBirminghamin person

Outcome

Claimant fails

Individual claims

Direct Discrimination(sex)failed

The tribunal found no evidence that the reason for the University's handling of the 2020 grievance was because the Claimant was a man. The reason was that the University had genuine concerns about the merits of the allegations against BCD and the difficulty of investigating allegations from September 2019 which the Claimant had initially said he did not want to pursue.

Victimisationfailed

The tribunal found no connection between the alleged detriments (failure to investigate properly, failure to keep claimant informed, failure to interview the alleged perpetrator) and the fact that the Claimant had raised grievances alleging sexual harassment. The University's actions were found to be in good faith for legitimate operational reasons, including the Claimant's own refusal to cooperate at times.

Detrimentfailed

The tribunal found that the Claimant did not make a protected disclosure because he did not reasonably believe there was a legal obligation on universities to submit an annual statement on research misconduct to Parliament. In any event, the alleged detriments (not investigating properly, alleging non-cooperation) were not connected to any disclosure. The University's actions were found to be reasonable and in good faith.

Facts

The Claimant was employed by the University from 1994 to 2023, retiring on partial ill-health grounds aged 60. He raised a grievance in September 2020 alleging sexual harassment and assault by a colleague (BCD) at a conference in September 2019. The Claimant was dissatisfied with how the University handled this and subsequent grievances, believing the University favoured a competing research group (City-REDI) associated with BCD. He had a history of grievances dating back to 2018 about promotion, alleged misuse of resources, and professional disappointments. In August 2021 he submitted a research integrity complaint. He brought tribunal claims alleging sex discrimination, victimisation, and protected disclosure detriment in relation to how these matters were handled.

Decision

The tribunal dismissed all claims. It found no evidence that the University's handling of the grievances was because the Claimant was a man, or because he had raised grievances alleging sexual harassment, or because he made disclosures about research integrity. The tribunal found the University acted in good faith for legitimate operational reasons. The Claimant did not make a protected disclosure because he did not reasonably believe there was a legal obligation to submit annual statements on research misconduct to Parliament. Most claims would also have failed on time limit grounds.

Practical note

A litigant in person's subjective belief that they have been wronged does not establish discrimination or victimisation; the tribunal must find objective evidence that the protected characteristic or protected act was the reason for the treatment, and procedural dissatisfaction alone, even if justified, does not meet this threshold.

Legal authorities cited

Islington Borough Council v Ladele [2009] ICR 387 EATConcentrix CVG Intelligent Contact Ltd v Obi [2022] EAT 149Liverpool Heart and Chest Hospital NHS Foundation Trust v Poullis [2022] EAT 9Mervyn v BW Controls Ltd [2020] EWCA Civ 393Ibekwe v Sussex Partnership NHS Foundation Trust [2014] UKEAT 0072_14_2011NHS Manchester v Fecitt [2011] EWCA Civ 1190South Wales Police Authority v Johnson [2014] EWCA Civ 73Ayodele v Citylink Ltd & Anor [2017] EWCA Civ 1913Warburton v Northamptonshire Police [2022] EAT 42Nagarajan v London Regional Transport [2000] 1 AC 501Anya v University of Oxford [2001] ICR 847

Statutes

EQA 2010 s.123EQA 2010 s.27EQA 2010 s.23EQA 2010 s.13ERA 1996 s.48(3)ERA 1996 s.48(2)ERA 1996 s.47BERA 1996 s.43B(1)EQA 2010 s.136

Case details

Case number
1302171/2022
Decision date
29 January 2025
Hearing type
full merits
Hearing days
8
Classification
contested

Respondent

Sector
Represented
Yes
Rep type
barrister

Employment details

Role
Associate Professor in the School of Geography, Earth and Environmental Sciences
Service
29 years

Claimant representation

Represented
No