The Equality Act covers victimisation that occurs *after* employment ends (e.g., providing a bad reference because the employee brought a discrimination claim).
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Coote v Granada Hospitality Ltd [1999] ICR 100
The Honourable Mr Justice Morison (President), Mr D J Jenkins MBE
Victimisation; EU law requires protection against victimisation even after the employment relationship has ended.
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Relaxion Group plc v Rhys-Harper [2003] IRLR 484 [judgment]
Lord Nicholls of Birkenhead, Lord Hope of Craighead, Lord Hobhouse of Woodborough, Lord Scott of Foscote, Lord Rodger of Earlsferry
Discrimination; post-employment; discrimination legislation covers acts (like references) occurring after employment ends.
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Pothecary Witham Weld v Bullimore [2010] ICR 1008
Lord Justice Underhill (President), Mr A Harris
Discrimination; victimisation; a bad reference given by an ex-employer is actionable.
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Jessemey v Rowstock Ltd [2014] IRLR 361 [judgment]
Lord Justice Maurice Kay, Lord Justice Ryder, Lord Justice Underhill
Victimisation; post-employment; the Equality Act prohibits victimisation even after employment has ended.