KATY ANGLISS v University of Warwick — 2026

Ms Angliss worked for the University of Warwick from 20 May 2013 until her dismissal on 4 June 2024. Her January 2023 promotion application contained a Head of Department statement that had changed from unsupportive to supportive and included Professor Clark's signature. The tribunal rejected her final-hearing account that Professor Clark had emailed her the version she submitted. That account had not been clearly raised during the investigation, disciplinary hearing or appeal, and the claimed email was not produced. The tribunal found her evidence unreliable and, where evidence conflicted, generally preferred the University's witnesses after considering each conflict on its merits.

Applying the British Home Stores v Burchell test, the tribunal found that the University genuinely believed Ms Angliss had committed misconduct and had ample reasonable grounds for that belief. The disciplinary material included her statements during the investigation that she had used the earlier Head of Department statement and signature, had merged the signature into the application, and could not recall whether she had changed the statement. Professor Elliott's investigation fell within the range of investigations open to a reasonable employer.

The tribunal found that the delay in the disciplinary process did not make the dismissal unfair. Parts of the delay arose from Ms Angliss's sickness absence and the handling of her grievances, and she had known of the disciplinary hearing for more than a year before receiving 15 days' notice of the May 2024 hearing. The tribunal rejected allegations of bias, conflicts of interest and predetermination, found no material failing in the appeal, and held that dismissal was within the range of reasonable responses. The University had found that a relatively senior academic made a fraudulent statement and used Professor Clark's signature without permission, which breached trust and confidence.

For the sex and age claims, the tribunal found that the grievance raised on 17 January 2024 was dealt with through the disciplinary process in line with the University's policy, so the alleged failure to hear it was not established. The allegation that Professor Ward had a negative bias towards women was unsupported by examples or other evidence and was not proved. The named comparators concerned the promotion process rather than the acts pleaded; they were also the same age as or older than Ms Angliss for the age claim, and none was shown to have faced an accusation of falsifying documents in materially similar circumstances. The tribunal found no less favourable treatment compared with an actual or hypothetical comparator.

The tribunal found that the reason for dismissal was the University's genuine belief that Ms Angliss had committed gross misconduct, not her sex or age. If there had been a failure to hear her grievance separately, the reasons were the disciplinary policy and the fact that the issues were addressed in the disciplinary process, not either protected characteristic. Under the Igen v Wong and Efobi burden-of-proof approach, she had not proved facts from which discrimination could be inferred, so the burden did not shift. All three claims were dismissed; the remedy issues did not require determination and no award was made.