Stigma: A limiting principle allowing multiple-consciousness in anti-discrimination law?

In 2004, a complaint was brought by Kamlesh Bahl1 against her employer, the Law Society. Bahl claimed that she had been the victim of discrimination on the grounds of her race and gender. According to Peter Gibson LJ, it was not possible for her to claim race and gender as a single combined ground of discrimination: these two aspects had to be treated separately and independent evidence in support of each brought forward. In other words, the law did not accommodate the notion that Bahl may have been the victim of discrimination because she was a black woman per se – she could be recognised as a victim of discrimination due to race or gender, but not both together.