The interest of this judgment is in the comments made by the EAT President, Elias J, on how to apply the 13 point guidance on the burden of proof rules in discrimination cases, as provided by the Court of Appeal in 2005 (in Igen Ltd v Wong [2005] ICR 931). A black Housing Officer claimed that he had been dismissed because he had raised allegations of bullying by reason of his race. He lost claims for race discrimination and victimisation at an employment tribunal and appealed to the EAT. He lost again.
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