Cases2200521/2023

Claimant v Crowe UK LLP

12 March 2024Before Employment Judge JoffeLondon Centralremote video

Outcome

Other

Individual claims

Direct Discrimination(age)not determined

This preliminary hearing concerned only whether partnership-era claims were in time and whether bonus claims should be struck out. Tribunal found prima facie continuing act and declined to strike out, but did not determine liability on the merits.

Indirect Discrimination(age)not determined

Claimant alleged PCPs in LLP Deed (Age 65 Rule) and practices constituted indirect discrimination. Tribunal found prima facie case of continuing discriminatory state of affairs but made no findings on liability.

Victimisationnot determined

Claimant alleged victimisation in relation to bonus decisions after raising protected disclosures and discrimination concerns. Not substantively determined at this hearing.

Detrimentnot determined

Claimant alleged detriment under Fixed-term Employees Regulations and protected disclosure detriment. Tribunal declined to strike out but made no findings on liability.

Unlawful Deduction from Wagesnot determined

Claimant alleged unlawful deductions relating to bonus payments based on alleged Remuneration Agreement. Tribunal found claims not bound to fail given factual disputes but made no determination on merits.

Facts

The claimant was a senior accountant who worked as a partner at the first respondent professional services firm from 2008 to 31 December 2020, when he turned 65. The LLP Deed contained retirement provisions with normal retirement age of 60, extension to 65 with agreement. After negotiations, he became a fixed-term employee from 31 December 2020 to 30 September 2022. He alleged that he was forced to relinquish his partnership due to his age, that promised remuneration arrangements were not honoured, and that he was subjected to detriments when he raised concerns about discriminatory treatment.

Decision

The tribunal refused the respondents' application to strike out the partnership claims as out of time, finding a prima facie case of conduct extending over a period that spanned both the partnership and employment periods. The tribunal also refused to strike out the bonus claims, finding they were not bound to fail given substantial factual disputes about the existence and content of an alleged Remuneration Agreement.

Practical note

A change in the statutory relationship between claimant and respondent within Part 5 of the Equality Act (e.g., from partner to employee) does not prevent earlier and later acts being considered as conduct extending over a period for time limit purposes if there is a prima facie case of a continuing discriminatory state of affairs.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Aziz v FDA [2020] EWCA Civ 3204Seldon v Clarkson Wright & Jakes [2012] UKSC 16Commissioner of Police of the Metropolis v Hendricks [2003] ICR 530Parr v MSR Partners LLP [2022] EWCA Civ 24Sougrin v Haringey Health Authority [1992] ICR 650Edinburgh City Council v Kaur [2013] CSIH 32E v X, L and Z (UKEAT/0079/20/RN)Mechkarov v Citibank NA [2016] ICR 1121Twist DX Limited v Armes [2020] 10 WLUK 604Balls v Downham Market High School [2011] IRLR 217Abertawe Bro Morgannwg University Health Board v Ferguson [2013] ICR 1108Robertson v Bexley Community Centre [2003] IRLR 434Keeble v British Coal Corporation [1997] IRLR 336Southwark LBC v Afolabi [2003] ICR 800

Statutes

Employment Tribunals Rules of Procedure 2013 r.39Equality Act 2010 s.123(3)Equality Act 2010 s.123Limitation Act 1980 s.33Equality Act 2010 s.25Equality Act 2010 s.39Equality Act 2010 s.45Equality Act 2010 s.120Fixed-term Employees (Prevention of Less Favourable Treatment) Regulations 2002Employment Tribunals Rules of Procedure 2013 r.37

Case details

Case number
2200521/2023
Decision date
12 March 2024
Hearing type
preliminary
Hearing days
1
Classification
procedural

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Global Head of Social Purpose and Non-Profits
Service
15 years

Claimant representation

Represented
Yes
Rep type
barrister