Case 8000247/2025 · Employment Tribunal
Ms M Idris v - Partner Anyiso SCIO — 2025
- Case reference
- 8000247/2025
- Decision date
- 2 September 2025
- Jurisdiction
- Scotland
- Judge
- Employment Judge D Hoey
- Venue
- Glasgow
Parties
2 namedClaimant
Ms M Idris
Respondent
Key findings
Tribunal's reasoningThe claimant, Ms M Idris, was employed by Partner Anyiso SCIO as a community development officer on a fixed-term contract. The tribunal found that relations between her and Ms Ezechi, the manager, deteriorated over workplace exchanges about hours, a funding application, heating in a room, a duplicate gift application, an unrecorded donation, hot water for workshops, and the claimant's use of WhatsApp. The claimant also raised a pay concern and later emailed health and safety concerns on 19 December 2024. The tribunal found that the respondent decided the claimant's employment should end because Ms Ezechi believed the claimant had not followed instructions, had not followed policy, and had breached confidentiality.
On the race discrimination case, the tribunal found that the alleged remarks about Arab women on 17 June 2024 were not made, and that the alleged comments about career progression and ethnicity being a barrier were not established. It also found that the alleged public criticism over a consent form was not established. Where treatment was established, including the dismissal and removal from systems, the tribunal found it would have been meted out in the same way to any employee in materially similar circumstances and was not less favourable treatment because of race.
The harassment complaint related to race was also dismissed. The tribunal found that the alleged acts either did not occur as alleged or were not related to race. In relation to the 11 December 2024 duplicate funding application discussion and the 20 December 2024 removal from WhatsApp and respondent systems, the tribunal found the conduct arose from Ms Ezechi's view that the claimant had made errors, not from the claimant's race. It further found that the conduct did not have the purpose or effect of violating dignity or creating an intimidating, hostile, degrading, humiliating or offensive environment.
For whistleblowing, the tribunal accepted that the claimant had made two protected disclosures: the 18 July 2024 pay concern and the 19 December 2024 health and safety email. It did not find that the claimant raised a disclosure at the 9 December 2024 informal meeting. The tribunal found no detriment caused by the disclosures: the claimant was removed from systems because Ms Ezechi believed she had breached confidentiality and was proceeding towards dismissal, and Ms Ezechi had not read the 19 December email before that decision. The alleged hostility, exclusion from events, and criticism were not established as disclosure-related detriments.
The automatic unfair dismissal complaint under section 103A ERA 1996 failed. The tribunal found the sole or principal reason for dismissal was the accumulation of conduct-related issues as seen by Ms Ezechi: alleged failure to follow instructions, failure to follow policy, unrecorded donated items, and breach of confidentiality. It rejected the submission that the claimant's disclosures were a sole or principal reason for dismissal. The judgment records that the indirect discrimination complaint had been withdrawn at the hearing and dismissed.
Claims and outcomes
5 findings recorded| Claim type | Issue or finding | Outcome | Protected characteristic | Award |
|---|---|---|---|---|
| Other | The indirect discrimination complaint was withdrawn at the hearing; the judgment also records it as dismissed. | Withdrawn | Race | — |
| Race discrimination | The tribunal rejected the alleged direct race discrimination acts, including alleged remarks about Arab women and career progression comments, and found the dismissal, duplicate funding discussion, and removal from systems were not because of race. | Dismissed | Race | — |
| Harassment | The tribunal found the alleged acts were not related to race and, where conduct was established, it did not have the required purpose or effect under section 26 Equality Act 2010. | Dismissed | Race | — |
| Whistleblowing | The tribunal accepted two protected disclosures had been made, but found no detriment was caused by them and no disclosure influenced the challenged treatment. | Dismissed | — | — |
| Unfair dismissal | This was an automatic unfair dismissal complaint under section 103A ERA 1996. The tribunal found the sole or principal reason for dismissal was the claimant's conduct, alleged failure to follow instructions and policies, and perceived breach of confidentiality, not protected disclosures. | Dismissed | — | — |
Legal tests applied
10 references- s.136 Equality Act 2010 burden of proof
- s.13 Equality Act 2010 direct discrimination
- s.23 Equality Act 2010 comparator
- s.26 Equality Act 2010 harassment
- Pemberton v Inwood
- s.43B ERA 1996 qualifying disclosure
- s.47B ERA 1996 detriment
- s.103A ERA 1996 automatic unfair dismissal
- Igen v Wong
- Madarassy v Nomura International
Official outcome judgment PDF
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