Case 2410964/2023 · Employment Tribunal
Mr I Laing v Solicitors Regulation Authority Limited and 4 others — 2026
- Case reference
- 2410964/2023
- Decision date
- 8 April 2026
- Jurisdiction
- England & Wales
- Judge
- Employment Judge Franey
Parties
6 namedClaimant
Mr I Laing
Key findings
Tribunal's reasoningThe judgment was a reserved preliminary hearing decision in combined proceedings brought by Mr I Laing against the Solicitors Regulation Authority, SRA employees Lewis Chatterley, Zoe Joynes and Nazma Bashir, and legal journalist Neil Rose. The claimant withdrew all claims in case number 2403431/2024 and withdrew all Equality Act complaints concerning the issue or revocation of a practising certificate or whether his name appeared on the Roll of Solicitors. Those matters were dismissed upon withdrawal.
All claims against Mr Rose were struck out. The Tribunal held that Mr Rose was not an employee of the SRA and that the claimant had no reasonable prospect of establishing that Mr Rose was acting as the SRA's agent when publishing the August 2020 article or making the February 2023 complaint to the SRA. It also rejected reliance on sections 111 and 112 Equality Act 2010, finding section 111 did not apply on the relationship alleged and section 112 could not assist because the claimant had no reasonable prospect of establishing an underlying contravention by the SRA.
The Tribunal rejected the SRA respondents' argument that complaints about the 2019-2021 SRA investigations should be struck out as res judicata. It held that the Birmingham Employment Tribunal's earlier out-of-time decision was not a merits determination and did not bar the claimant from arguing that later events formed part of a continuing act for limitation purposes. However, that did not preserve the claims once the Tribunal considered the merits of the later allegations.
The remaining complaints were treated as complaints of direct discrimination because of race and sex, harassment related to race and sex, and victimisation by reference to alleged protected acts. The Tribunal considered the pleaded later detriments: the September 2023 decision to investigate the claimant following Mr Rose's February 2023 complaint, subsequent investigation steps, alleged failures to deal properly with the claimant's complaints, and the 29 November 2024 decision to refer him to the Solicitors Disciplinary Tribunal. It found that the claimant's proposed comparators, Maria Williams and Tina Whitman, did not materially support an inference that race, sex or protected acts influenced the SRA's treatment.
The Tribunal found that the Rose complaint and associated documents provided an innocent and well documented reason for the SRA to investigate. It concluded that the claimant had no reasonable prospect of showing that the SRA respondents' treatment from May 2023 onwards amounted to less favourable treatment because of race or sex, conduct related to race or sex for harassment purposes, or treatment materially influenced by protected acts. The earlier complaints determined as out of time in Birmingham therefore had no reasonable prospect of being revived as part of a continuing discriminatory act. The applications to amend made on 25 February 2025, 14 March 2025 and 15 August 2025 were refused because the proposed amended claims also had no reasonable prospect of success.
Claims and outcomes
6 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Race discrimination | Direct discrimination complaints against Mr Rose were struck out because the claimant had no reasonable prospect of establishing Equality Act liability. Direct discrimination complaints against the SRA respondents, including complaints about the 2019-2021 investigations and later regulatory steps from 2023 onwards, were struck out as having no reasonable prospect of success. Complaints relating to the practising certificate or Roll were dismissed upon withdrawal. | Struck out | Race | — |
| Sex discrimination | Direct discrimination complaints against Mr Rose were struck out because the claimant had no reasonable prospect of establishing Equality Act liability. Direct discrimination complaints against the SRA respondents, including complaints about the 2019-2021 investigations and later regulatory steps from 2023 onwards, were struck out as having no reasonable prospect of success. Complaints relating to the practising certificate or Roll were dismissed upon withdrawal. | Struck out | Sex | — |
| Harassment | Harassment complaints related to race against the SRA respondents were struck out as having no reasonable prospect of success. The judgment also struck out all claims against Mr Rose because the claimant had no reasonable prospect of establishing Equality Act liability. | Struck out | Race | — |
| Harassment | Harassment complaints related to sex against the SRA respondents were struck out as having no reasonable prospect of success. The judgment also struck out all claims against Mr Rose because the claimant had no reasonable prospect of establishing Equality Act liability. | Struck out | Sex | — |
Legal tests applied
20 references- Rule 38 Employment Tribunal Procedure Rules 2024
- Sections 13, 26 and 27 Equality Act 2010
- Section 53 Equality Act 2010
- Sections 109 and 110 Equality Act 2010
- Sections 111 and 112 Equality Act 2010
- Section 120(7) Equality Act 2010
- Section 123(3)(a) Equality Act 2010
- Section 136 Equality Act 2010
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Official outcome judgment PDF
Gov.uk primary recordThe 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.
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