“In the absence of direct evidence on an issue of less favourable treatment on racial grounds, the Tribunal may make inferences from other facts which are undisputed or are established by evidence. However, in the absence of adequate material from which inferences can be properly made, a Tribunal is not entitled to find a claim proved by making unsupported legal or factual assumptions about disputed questions of less favourable treatment on racial grounds. This is so whether the discrimination is alleged to arise from conscious or subconscious influences operating in the mind of the alleged discriminator.”
“We wish to emphasise this last question. The provisions to which we have referred find their place in legislation concerned with equality. It is not purpose of such legislation to address all forms of bullying or antisocial behaviour in the workplace. The legislation therefore does not prohibit all harassment, still less every argument or dispute in the workplace; it is concerned only with harassment which is related to a characteristic protected by equality law… In our judgement, when a Tribunal is considering whether facts been proved from which it could conclude that harassment was on the grounds of sex or race, it is always relevant, at the first stage, to take into account the context of the conduct which is alleged to have been perpetrated on the grounds of sex or race. The context may, for example, point strongly towards or strongly against a conclusion that harassment was on the grounds of sex or race. The Tribunal should not leave the context out of account at the first stage and consider it only as part of the explanation at the second stage, after the burden of proof has passed…” 97. I respectfully agree. It seems to me that an inference in this case appears to have been drawn that unwanted conduct was attributable to the Claimant’s protected beliefs without any regard for the context of that conduct. Whilst it is for the Tribunal to determine that context in light of the facts, here the Tribunal’s own findings pointed strongly against a conclusion that the asserted acts of harassment had anything whatever to do with his protected beliefs, and no evidential basis to support the contrary conclusion, beyond merely the Claimant’s assertions, has been identified. 98. Even if I am wrong about that, in my judgment it was not open to the Tribunal in relation to any of these incidents as found, to conclude that there was unlawful harassment on the ground of the Claimant’s protected beliefs. This was a case where the Tribunal found that the respondent’s purpose in relation to the three incidents was to create an intimidating, hostile or humiliating environment for the Claimant. But as Elias LJ said in Land Registry v Grant[2011] ICR 1390 at [47]: “Tribunals must not cheapen the significance of these words. They are an important control to prevent trivial acts causing minor upsets being caught by the concept of harassment .”