Serco Ltd t/a Education Bradford & ors v Quarshie - Different burden of proof in "race discrimination" (RRA s.1) and "victimisation" (RRA s.2) claims [2006] EAT

The EAT rules that there was no error of law in an Employment Tribunal's finding direct race discrimination under Race Relations Act 1976 s.1(2) while dismissing a claim of victimisation under s.2. The 2003 rules re shifting of the burden of proof apply to race discrimination claims but not victimisation claims (ie claims that an employee was victimised because he had made an allegation of race discrimination).