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Kulkarni v (1) NHS Education Scotland (2) Large - "Qualifications bodies" in discrimination claims [2012] EAT

A body providing educational services but that does not confer any authorisation, qualification, recognition, enrolment, approval or certification is not a "qualifications body" under Equality Act 2010.

Mr Kulkarni was a consultant orthopaedic surgeon employed at Wishaw General Hospital - he was employed by neither NHS Education Scotland (a statutory body which has as its principal objective the provision of educational services for those who work in the NHS in Scotland) nor Mr Large (who himself worked for Ayrshire and Arran Health Board, allocating trainee surgeons on behalf of such organisations). Mr Kulkarni complained of race discrimination in the fact that he had been allocated no trainee surgeons for 5 years (something of value in terms of job satisfaction training others, esteem, prestige, and the practical assistance it provides)

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