• Robert Spicer

Bristol race discrimination case: Wiltshire police




Case Lungu v Chief Constable of Wiltshire Police (2015) Eq Opp Rev 259:23, Bristol ET

Facts L, a black man of Zimbabwean ethnicity, is a police constable employed by CCWP. The Wiltshire force has 16 black officers out of a total of 1072. He was denied the opportunity for promotion because his line manager refused to recommend him, having reduced his appraisal scores with no explanation. His line manager allegedly complained to L about his body odour, saying that this was caused by the greasy stuff which he put on his skin. L complained of direct race discrimination and racial harassment.

Decision 1. The line manager’s comments about body odour were clearly linked to the fact that he was black. This was unwanted conduct which had the effect of violating his dignity.

  1. The reduction of scores on L’s appraisal was direct race discrimination. There was no real explanation of why the scores had been changed. It was clearly appropriate to infer that it had been done because of L’s race.

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