“166. The dismissal of the applicant from the post of judge affected a wide range of his relationships with other persons, including relationships of a professional nature. Likewise, it had an impact on his “inner circle” as the loss of his job must have had tangible consequences for the material well-being of the applicant and his family. Moreover, the reason for the applicant’s dismissal, namely breach of the judicial oath, suggests that his professional reputation was affected.”
“It is therefore now established that both employment matters and situations involving HIV-infected persons fall within the scope of private life.”
“It is clear that the applicant’s dismissal resulted in the stigmatisation of a person who, even if they were HIV-positive, had not shown any symptoms of the disease. That measure was bound to have serious repercussions for his personality rights, the respect owed to him and, ultimately, his private life. To that must be added the uncertainty surrounding his search for a new job, since the prospect of finding one could reasonably have appeared remote having regard to his previous experience. The fact that the applicant did find a new job after being dismissed does not suffice to erase the detrimental effect of his dismissal on his ability to lead a normal personal life.” 33. The Claimants were both dismissed for redundancy. It was not suggested that their selection for redundancy was for any reason which would affect their reputation, their private or professional relationships. Redundancy can be regarded as perhaps the least blameworthy reason for dismissal. None of the authorities relied upon by Ms Criddle support the proposition that dismissal of itself engages Article 8. In my judgment the claims in this appeal do not engage Article 8. 34. As Mr Capewell submitted Article 14 is inapplicable if Article 8 is not engaged. It adds nothing in the circumstance where the facts of the case are not within the ambit of Article 8. Since I have concluded that Article 8 is not engaged I will deal only briefly with the submission advanced on Article 14. 35. Article 14 prohibits discrimination on various grounds including “other status”
“The Court will therefore establish, first, whether there has been a difference of treatment of the applicants, and, if so, whether the facts of the case fall within the ambit ofArticle 8 of the Convention in order to rule on the applicability of Article 14.” [39] The Government of Lithuania had explained that not all former KGB officers suffered restrictions on their future employment. The Court observed that the impugned domestic legislation did not restrict the employment prospects of all former collaborators of the Soviet Security Service. An amnesty rule applied to members of the KGB who had only been engaged in criminal, as opposed to political investigations during their time at the KGB. 37. The ECHR in Sidabras therefore did not decide whether being a past member of the KGB was “other status” within the meaning of Article 14. Whilst having worked for the KGB was mentioned by the Court in deciding whether there was a difference in treatment between them and those who had not worked for the KGB, in this context it also stated: “In addition, in view of the Government’s argument that the purpose of the Act was to regulate the employment prospects of persons on the ground of their loyalty or lack of loyalty to the state, there has also been a difference of treatment between the applicants and other persons in this respect. For the Court, this is the appropriate comparison in the instant case for the purposes of Article 14.” [41] 38. The case of Sidabras proceeded on the basis that the former occupation of the applicants taken together with their personal characteristics attached to them by virtue of their particular duties brought them within the ambit of Article 8. The issue of whether having been a KGB agent was such “other status” was not a question which the ECHR was asked to decide. The issue under Article 14 was whether the difference in treatment of former members of the KGB who were regarded as having been engaged in political investigations and to whom the characteristic of lack of loyalty attached had no objective and reasonable justification and whether the restriction on their future employment was proportionate. Accordingly, Sidabras is not authority for the proposition that occupation is to be treated as “other status” within Article 14. 39. In R(RJM) v Work and Pensions Secretary [2009] IAC 311 Lord Neuberger [41] agreed with the approach taken by Lord Walker in paragraph 5 to “personal characteristics” which had been used by the ECHR in examining “other status” in Article 14. Lord Neuberger held: “Further, while reformulations are dangerous, I consider that the concept of “ personal characteristic” (not surprisingly, like the concept of status) generally requires one to concentrate on what somebody is, rather than what he is doing or what is being done to him. Such a characterisation approach appears not only consistent with the natural meaning of the expression, but also with the approach of the ECtHR and of this House to the issue. 40. The proposition advanced by Ms Criddle that the occupation of the Claimants, Parks Police Constables, of itself constitutes “other status” for the purpose of Article 14 is not supported by domestic authority nor that of the ECHR. No argument or justification under Article 14 such as was considered in The Belgian Linguistic Case (No2) [1979-80] 1 EHRR 252 was advanced before the ET. The Secretary of State is not a party to these proceedings. 41. As with the Article 14 argument, the contention that ERA section 200(2) fails to safeguard the Claimants’ Article 6 rights fails for the same reason as the inapplicability of Article 14. On the facts under consideration there are no Article 8 rights to be safeguarded. Whilst submissions were developed by both counsel, in light of the conclusion on the non-applicability of Article 8 whether on its own or together with Article 14, a decision on this issue is unnecessary to the outcome of the appeal. Article 11 42. It was said by the ECHR in Demir v Turkey[2009] 48 EHRR 54 that: “… the Court has always considered thatArticle 11 of the Convention safeguards freedom to protect the occupational interest of trade – union members by the union’s collective action.” [140] The Court identified as being amongst the “essential elements of the right of association” the right for a trade union to seek to persuade the employer to hear what it has to say on behalf of its members.” [145] 43. The right which is claimed in these cases is a remedy for failing to consult the trade union, UNISON, over proposed redundancies. Collective bargaining over employees’ interests falls within Article 11. Keith J held in R (Boots Management Services Ltd.) v CAC[2015] IRLR 15 at [25]: “It is important to note that the right to form and join trade unions in Article 11 is expressed to be “for the protection of [one’s] interests”
“The imposition of lawful restrictions on the exercise of these rights by members of the armed forces, of the police or the administration of the State.” 46. The Court in Demir did not accept that in the case of the groups mentioned in Article 11.2 which include the police, that “ “Lawful” in the second sentence of Article 11(2) requires no more than that the restriction in question should have a basis in national law, and not be arbitrary and that it does not entail any requirement of proportionality.” 47. As Mr Capewell rightly stated, evidence and submissions on proportionality would be a matter for the Secretary of State who has not been joined to these proceedings. This court is in no position to express a view on the proportionality of the apparent exclusion by TULR(C)A section 280 of UNISON representing the Parks Police from the right to claim a declaration and a protective award under section 189. Without a decision on whether section 280 satisfies Article 11.2 there can be no decision on whether Article 11 applies to these claims or whether Article 6 is engaged. 48. UNISON also rely on the Collective Redundancies Directive to support their claim to a protective award under TULR(C)A section 189 for Wandsworth not consulting it over the proposed redundancies of the Parks Constables. The response of Mr Capewell that the Collective Redundancies Directive expressly excludes from its scope employees of public authorities and that the Claimants fall within this group is clearly right. Article 1.2(b) provides: “This Directive shall not apply to – … (b) workers employed by public administrative bodies or by establishments governed by public law…”
“(2) In subsection (1) “Police Service” means – (a) Service as a full member of a [virtue]constabulary maintained by an enactment, meaning a body whose sole function is to operate a police force and whose obligations in doing so are prescribed by legislation, or (b)… Service in any other capacity by virtue of which a person has the powers or privileges of a constable in full.”