Case 2206164/2021 · Employment Tribunal

Ms A Reindorf, Counsel For the v Ms R M White (3rd respondent) — 2022

Case reference: 2206164/2021
Decision date: 30 September 2022
Jurisdiction: England & Wales
Judge: Employment Judge B Beyzade Representation
Venue: London Central

Indexed: 21 May 2026

Parties

2 named

Claimant

Ms A Reindorf, Counsel For the

Respondent

Ms R M White (3rd respondent)

Key findings

Tribunal's reasoning

The tribunal was dealing with preliminary issues and a strike-out application in claims 2206164/2021 and 2206708/2021, not a final merits hearing. The claimant had pleaded direct discrimination, harassment and victimisation based on religion or belief, with the protected beliefs described as gender critical and as a talking-therapy view about gender dysphoria. The disputes concerned the first respondent, UKCP and, in the second claim, Ms Gawler-Wright.

On UKCP's status, the tribunal held that UKCP was not a qualifications body for the trainee-listing aspect under sections 53 and 54 EqA. It found that inclusion on the trainee list did not confer a relevant qualification, did not better enable the claimant to practise psychotherapy, and was a consequence of enrolment on the first respondent's course rather than a formal UKCP declaration of competence. The tribunal accepted, however, that UKCP was a trade organisation within section 57(7)(c), because its members carry on psychotherapy and the organisation exists for the purposes of that profession; the claimant could therefore continue to advance the claims against UKCP on that basis.

In the second claim, the tribunal struck out the victimisation complaint against Ms Gawler-Wright because the material before it showed her to be an independent contractor providing training, not UKCP's agent. It was not satisfied that her past or present roles with UKCP, the presence of a UKCP staff member, or the surrounding communications established actual or ostensible authority. The tribunal therefore held that the agency-based case against her had no reasonable prospect of success.

The tribunal also struck out the aspect of the first claim that alleged UKCP was liable as principal for the termination of the claimant's contract with the first respondent under sections 109 and 110 EqA. By contrast, it refused to strike out the remaining allegations, including the section 111 allegation that UKCP instructed, caused or induced the termination, and the remaining discrimination, harassment and victimisation allegations against UKCP. It declined to make a deposit order. The judgment therefore left the substantive claims against UKCP to proceed to a later hearing.

Claims and outcomes

7 findings recorded

This case has mixed outcomes under at least one legal claim type. A tribunal can uphold some allegations and dismiss others under the same legal head, so rows below may represent separate issues or allegation groups from the judgment.

Claim type	Issue or finding	Outcome	Protected characteristic	Award
Religion or belief discrimination	First Claim against UKCP under sections 53 and 54 of the Equality Act 2010. The tribunal held UKCP was not a qualifications body for the trainee-listing aspect because inclusion on the trainee list did not confer a relevant qualification or better enable the claimant to practise; it held UKCP was a trade organisation under section 57(7)(c), so the underlying claim could continue on that basis.	Other	Religion or belief	—
Harassment	First Claim harassment allegation against UKCP under sections 53 and 54. The tribunal rejected jurisdiction on the qualifications-body route but held the claim could continue under the trade-organisation route in section 57.	Other	Religion or belief	—
Victimisation	First Claim victimisation allegation against UKCP under sections 53 and 54. The tribunal held there was no jurisdiction on the qualifications-body basis, but UKCP was a trade organisation within section 57(7)(c), so the claim was not finally disposed of.	Other	—	—
Victimisation	Second Claim victimisation allegation against UKCP. The tribunal did not strike this part out at the preliminary hearing and directed further case management; it noted only a provisional view that the claim against UKCP might be vulnerable.	Other	—	—
Victimisation	Second Claim against Ms Gawler-Wright was struck out under Rule 37(1)(a). The tribunal found she was an independent contractor delivering training and was not acting as UKCP's agent; there was no actual or ostensible authority shown.

Legal tests applied

6 references

Official outcome judgment PDF

Gov.uk primary record

The official judgment PDF on gov.uk contains the tribunal's outcome, reasoning, and any remedy details. Where this page does not yet show extracted outcomes for every claim, use the PDF as the authoritative source.

Published on gov.uk under the Open Government Licence v3.0.

How we got this data

Case essentials (reference, date, judge, venue, country, claim categories) are extracted from the structured metadata gov.uk publishes alongside each decision. Parties and monetary figures are extracted from the judgment PDF text. Key findings and per-claim outcomes require a second extraction pass that is not yet complete for this case — until then, the primary source linked above is the authoritative record. See full methodology.

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