Discrimination - Principal Liable to Contract Worker

In Leeds City Council v Woodhouse the claimant worked for a commercial organisation responsible for the management and maintenance of Leeds council housing.  He alleged that he had been racially abused, to his face and behind his back, by an employee in the council's housing team with whom he had dealings at work.

The Court of Appeal has upheld an EAT decision that Leeds City Council was liable for these acts of racial discrimination and harassment by one of its employees.  In doing so it confirmed the wide application of s.7 of the Race Relations Act, which states that it is unlawful for a principal to discriminate against a contract worker on grounds of race.

In its judgment, the Court of Appeal dealt with the following questions – do contract workers need to be under the principal's managerial power or control in order to bring such a claim directly against them? Should the court ask whether they were treated as employees? Or whether the principal controlled