MoJAn Employment Tribunal has found that the Greater Manchester Police (“GMP”) discriminated against and victimised a black police officer by failing to investigate his grievances regarding racism in the police force.

The Manchester Employment Tribunal found that Detective Constable Paul Bailey had been ordered to return from a secondment without any explanation and that the GMP victimised him by failing to investigate his race discrimination complaints about his secondment being ended. The Tribunal also found that the failure to refer DC Bailey’s complaints to the GMP’s Professional Standards Branch amounted to direct race discrimination and victimisation.

DC Bailey, who was worked at the GMP for 24 years and is the chairman of the Black and Asian Police Association, previously brought a claim against the GMP in 2008 for direct race discrimination when he was disciplined for wearing traditional African dress. This claim was settled through a ‘compromise agreement’ and the parties involved agreed that he should be seconded to the Warrington-based North West Crime Regional Unit, only for the secondment to be terminated without explanation.

The Employment Tribunal upheld DC Bailey’s claims for direct race discrimination and victimisation, finding that the GMP had victimised him by failing to investigate his complaint that he had been discriminated against and, further, that the police force had directly discriminated against him by failing to refer his complaint to the Professional Standards Branch.

The Employment Tribunal will determine what compensation is to be awarded to DC Bailey at a hearing later this year.

DC Bailey commented on the decision of the Employment Tribunal after the judgment was released: “I feel vindicated by this decision. Getting to this ruling has taken a heavy toll on my health. I have spent the past weeks and months battling to expose the victimisation and discrimination I have suffered. But I look forward to this matter being concluded soon so I can put it behind me.”

Detective Chief Constable Ian Hopkins made the following statement: “Greater Manchester Police acknowledges the judgment made by the employment tribunal with regard to Detective Constable Paul Bailey… This is something we as a force take extremely seriously. The organisation will always try to resolve workplace complaints in the most appropriate forum and this issue, together with the other important lessons the tribunal identified, is something we will look to learn from as we move forward.”

Chris Hadrill, an employment solicitor at Redmans, commented on the case: “Employers must take steps to investigate complaints of discrimination in the workplace promptly and fairly, otherwise they risk employees claiming that they have been victimised for these complaints.”


Redmans Employment Team deal with employment matters for both employers and employees, including drafting employment contracts and policies, advising employers and employees on compromise agreements, handling day-to-day HR issues, advising on restructures, and handling Employment Tribunal cases for both employers and employees

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