(c) Protection beyond s 2A of the SDA 1975 : As mentioned above, in reflecting actual decision in P v S, s 2A only covered direct discrimination in the field of employment and occupation. However, subsequent cases have broadened the protection beyond the strict wording of s 2A. The decision in suggests that the SDA 1975 as a whole may apply to transsexuals. The European Court of Human Rights in Goodwin v UK held that the

doi:10.4324/9781843145585-32

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(c) Protection beyond s 2A of the SDA 1975

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ABSTRACT

The EAT upheld the decision of the industrial tribunal that the SDA 1975 could, in the light of P v S, be construed so as to cover unfavourable treatment following a person’s statement of intention to undergo gender reassignment.