Cases8000580/2023

Claimant v University of Aberdeen

28 June 2024Before Employment Judge N M HosieScotlandin person

Outcome

Claimant fails

Individual claims

Direct Discrimination(disability)struck out

The claimant's direct discrimination claim was misconceived because he compared himself with other disabled applicants under the Guaranteed Interview Scheme rather than non-disabled applicants. Section 13 of the Equality Act 2010 requires comparison with someone who does not share the protected characteristic. The claim had no reasonable prospect of success and was struck out under Rule 37(1)(a).

Facts

The claimant, a disabled person, applied for a position with the University of Aberdeen and expected to be interviewed under the respondent's Guaranteed Interview Scheme for disabled applicants. He was not afforded an interview and brought a claim of direct disability discrimination. The claim was based on alleged unfair treatment compared with other disabled applicants under the same scheme. The respondent applied to strike out the claim, and the claimant applied to strike out the respondent's response.

Decision

The tribunal struck out the direct discrimination claim because it was misconceived. The claimant had compared himself with other disabled applicants rather than non-disabled comparators as required by section 13 of the Equality Act 2010. The claim had no reasonable prospect of success. The tribunal refused the claimant's application to strike out the respondent's response, finding no basis for it under Rule 37(1)(b).

Practical note

A direct discrimination claim under section 13 of the Equality Act 2010 must involve comparison with someone who does not share the claimant's protected characteristic; comparing treatment between members of the same protected group is misconceived and will be struck out.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Ahir v British Airways Plc [2017] EWCA Civ 1392Romanowska v Aspiration Care Ltd UKEAT/0015/14Mechkarov v Citi Bank NA [2016] ICR 1121Cox v Adecco & Others [2021] UKEAT/0339/19Wright v Nipponkoa Insurance (Europe) Ltd UKEAT/0113/14Hemdan v Ishmail [2017] ICR 486Tree v South East Coastal Services Ambulance NHS Trust UKEAT/0043/17HM Prison Service v Dolby [2003] IRLR 694Hassan v Tesco Stores Ltd UKEAT/0098/16Ukegheson v Haringey London Borough Council [2015] ICR 1285

Statutes

Employment Tribunals (Constitution and Rules of Procedure) Regulations 2013, Schedule 1, Rule 39Equality Act 2010 s.13Employment Tribunals (Constitution and Rules of Procedure) Regulations 2013, Schedule 1, Rule 37

Case details

Case number
8000580/2023
Decision date
28 June 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
education
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No