Heskett v Secretary of State for Justice  EWCA Civ 1487
Justification for pay freeze which caused indirect age discrimination.
Section 39 (2) (d) of the Equality Act 2010 provides that an employer must not discriminate against an employee by subjecting him or her to any detriment.
Indirect discrimination is defined in section 19. Subsections (10 and (2) read:
"(1) A person (A) discriminates against another (B) if A applies to B a provision, criterion or practice which is discriminatory in relation to a relevant protected characteristic of B's.