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Feminism: Sex and gender discussions

Consequences of ls v NHSE England court win, discuss & explore the detail of judgement, what this means for other cases and institutions

104 replies

SingleSexSpacesInSchools · 14/05/2026 09:15

https://didlaw.com/ls-v-nhse-england

Don't want valuable discussion of what this means and the detail of the case judgement to get lost in the other (very valid) threads.

Yesterdays case feels quote significant, would like to explore what it means!

LS v NHSE England - Didlaw

Didlaw can reveal that the Claimant in the above case, heard in Leeds ET for 6 days from 23 March 2026 has been successful in her discrimination claims against NHS England. The ET upheld the following claims: The claims:  The Claimant is employed by NH...

https://didlaw.com/ls-v-nhse-england

OP posts:
usernameinserthere · 14/05/2026 11:16

theilltemperedamateur · 14/05/2026 10:58

1.There was an arcane point about indirect discrimination as to a combination of more than one protected characteristic (eg muslim plus female) not being proscribed. LS could have prevailed on this point alone if they proved that both male and female muslims are disadvantaged relative to non-muslims by the provision of (only) mixed-sex services, but they didn't present the necessary evidence.

2.If they had prevailed on religious discrimination, the general tenor of the judgment suggests that this aspect could still have been mitigated by providing sufficient enclosed single-user facilities that muslims, rather than transgender people, could use, because of the numbers involved.

3.(A tribunal found against claimant in Kelly v Leonardo based on numbers. It was an unusual workplace, that had very few women, and lots of transwomen and enclosed single-user facilities, so Kelly was not deemed unjustifiably disadvantaged by having to use them.)

4.However, KELLY is superseded by the High Court (R on application by GLP et al v EHRC) finding that WR1992 require sufficient single-sex multi-user provision, and this was relied on in LS v NHS.

5.In addition, ET in LS v NHS found, based on experts' fact evidence, that mixed-sex only provision disadvantages all women, relative to men. (There was a similar finding in the Darlington case, but the tribunal in KELLY found the other way, and ignored WR1992 altogether.)

6.The tribunal then essentially pointed out that it would be absurd to potentially cram all the women into the enclosed single-user space whilst a handful of TWs had the run of the ladies etc.

7.This isn't binding, and it would be great to get it confirmed by the High Court. Because point 5. is ultimately based on fact evidence, it would be hard to overturn.

8.What intrigues me is that point 5. seems to apply irrespective of how the women feel about it. They could be wall-to-wall handmaidens, but, objectively, they are suffering illegal discrimination.

9.Also, although situations vary, this seems to support a developing appreciation that mixed-sex only provision is always illegal sex-discrimination, or at least that the onus is on the provider to prove otherwise. This applies to service providers as well as employers and is relevant to the EHRC guidance. The guidance already suggests that this is an issue to be addressed, but would be strengthened by confirmation from the High Court (this wasn't addressed by GLP v EHRC because that was not about a specific situation, and the judge wisely declined to make a universal finding about something that might turn out to be fact-dependent in some unforeseen way).

Edited

To add to this Kelly was beyond bat shit and is being appealled.

The judge said a cubicle within a single sex toilet room was actually a room itself so a woman being in that locked cubicle with a man in a locked cubicle next to her and sharing the same sinks was in compliance with the workplace regs. Anyone with an iota of wit knows that is bonkers and will be knocked out the park on appeal.

theilltemperedamateur · 14/05/2026 11:19

Hicc · 14/05/2026 10:22

I agree re the importance of this case.

I know it has been touched on before, but what will stop captured organisations from simply making all their toilet provision mixed sex, in the light of this, to avoid having to say no to the men wanting to use the womens? It is my understanding that if single sex facilities are provided, organisations must direct people to use the facility that matches their sex. But organisations don't have to provide single sex facilities do they? They can just have lockable cubicles for everyone?

Obviously there is a cost to this, but I can see some organisations preferring to do this rather than saying no to the trans identified men.

Employers have to provide sufficient single-sex multi-user provision under WR1992, confirmed by the High Court and enforceable by law.

Service providers still only have to contend with two non-binding fact-dependent findings (in this case and Darlington) that mixed-sex only provision is indirect sex-discrimination. We may need to keep these cases coming, and get them to the High Court.

SingleSexSpacesInSchools · 14/05/2026 11:20

(Irony is off the scale on the reddit discussion of this case https://www.reddit.com/r/transgenderUK/comments/1tcbywl/another_lawfare_attack/ )

OP posts:
KnottyAuty · 14/05/2026 11:21

Following closely - Faye’s tribunal helps the trickle down to NHS staff. Now we need to get the patient single sex spaces sorted out

theilltemperedamateur · 14/05/2026 11:24

usernameinserthere · 14/05/2026 11:16

To add to this Kelly was beyond bat shit and is being appealled.

The judge said a cubicle within a single sex toilet room was actually a room itself so a woman being in that locked cubicle with a man in a locked cubicle next to her and sharing the same sinks was in compliance with the workplace regs. Anyone with an iota of wit knows that is bonkers and will be knocked out the park on appeal.

Yes, that was the crazy judge who thinks that single-sex toilets are only required by moral propriety, on which our thinking has thankfully evolved. 🙄

SwirlyGates · 14/05/2026 11:29

SingleSexSpacesInSchools · 14/05/2026 11:20

(Irony is off the scale on the reddit discussion of this case https://www.reddit.com/r/transgenderUK/comments/1tcbywl/another_lawfare_attack/ )

Wish I hadn't read that. These crazy people walk among us.

Keeptoiletssafe · 14/05/2026 11:30

theilltemperedamateur · 14/05/2026 11:24

Yes, that was the crazy judge who thinks that single-sex toilets are only required by moral propriety, on which our thinking has thankfully evolved. 🙄

Oh yes moral propriety - I was just on another thread about the ponds on Hampstead Heath and could have done with that phrase. Sod health and safety, they want to make the facilities more private for moral propriety so all is then well. Nothing to see or hear here.

usernameinserthere · 14/05/2026 11:36

SwirlyGates · 14/05/2026 11:29

Wish I hadn't read that. These crazy people walk among us.

And are trying to undress in front of you. And think that stonewall law lets them.

usernameinserthere · 14/05/2026 11:38

KnottyAuty · 14/05/2026 11:21

Following closely - Faye’s tribunal helps the trickle down to NHS staff. Now we need to get the patient single sex spaces sorted out

Yes indeed @KnottyAuty

When we are at our most vulnerable the NHS are allowing the stronger sex to prey on us.

ItsCoolForCats · 14/05/2026 11:45

Surely the Kelly judgement can't survive on appeal? Any dates for the appeal for this yet?

Ereshkigalangcleg · 14/05/2026 12:00

MyAutumnCrow · 14/05/2026 10:16

But the binding law already exists, above the tribunals? So these tribunals can’t go any other way now.

The Peggie tribunal did, and the Kelly one. The GLP case was super helpful though.

usernameinserthere · 14/05/2026 12:12

ItsCoolForCats · 14/05/2026 11:45

Surely the Kelly judgement can't survive on appeal? Any dates for the appeal for this yet?

Yes I agree. Haven’t see a date pop up yet but will check in on the Kelly v Leonardo thread.

usernameinserthere · 14/05/2026 12:13

Ereshkigalangcleg · 14/05/2026 12:00

The Peggie tribunal did, and the Kelly one. The GLP case was super helpful though.

Yes GLP is High Court binding law. Decided after Peggie and Kelly.

They don’t survive on appeal.

MarieDeGournay · 14/05/2026 12:21

Hicc · 14/05/2026 10:22

I agree re the importance of this case.

I know it has been touched on before, but what will stop captured organisations from simply making all their toilet provision mixed sex, in the light of this, to avoid having to say no to the men wanting to use the womens? It is my understanding that if single sex facilities are provided, organisations must direct people to use the facility that matches their sex. But organisations don't have to provide single sex facilities do they? They can just have lockable cubicles for everyone?

Obviously there is a cost to this, but I can see some organisations preferring to do this rather than saying no to the trans identified men.

But organisations don't have to provide single sex facilities do they? They can just have lockable cubicles for everyone?
<looks around to see if Keeptoiletssafe is around to share her incredible store of knowledge on the subject - doesn't look like it so here goes with my inexpert opinion!>

It depends, but in some circumstances, yes, organisations do have to provide single sex facilities, acc. to Health and Safety and Workplace Regs.
Also under building regs for England
Approved Document T - Toilet accomodation
Building regs T1.
(1) Toilet accommodation in buildings other than dwellings—
(a) must consist of—
(i) reasonable provision for male and female single-sex toilets,
(ii) or where space precludes provision of single-sex toilets, universal toilets, and
(b) may consist of universal toilets in addition to single-sex toilets.

So 'Universal' i,e, mixed sex toilets - which BTW have to meet building regs specs, they can't just be any old toilet with a new badge stuck on it - may be provided instead of single-sex toilets, but only if there isn't enough space for the latter.
Otherwise they have to be in addition to single sex toilets.

That's just for England, there are different building regs elsewhere - but Doc T is a useful reference point for as it is a very clear and detailed plan for toilet provision in public buildings.

I don't think that making everything mixed sex is legal, in many circumstances, so it would not only be at great financial cost in the short term, but possibly other costs - legal, insurance - in the longer term.

They should keep it simple: men's/women's/accessible/optional mixed sex.

Hicc · 14/05/2026 12:30

Thanks @usernameinserthere and @MarieDeGournay
Have I understood correctly then, that Employers have to provide single sex facilities, but other organisations (shops, hotels, gyms etc) are not required to, and could get rid of women's facilities in favour of private but mixed sex facilities?

usernameinserthere · 14/05/2026 12:43

Hicc · 14/05/2026 12:30

Thanks @usernameinserthere and @MarieDeGournay
Have I understood correctly then, that Employers have to provide single sex facilities, but other organisations (shops, hotels, gyms etc) are not required to, and could get rid of women's facilities in favour of private but mixed sex facilities?

Case law at present is in respect of employer / employee relationships.

This isn’t relating to general services - but the EHRC guidance is to be issued and will cover some aspects of service provision.

It probably will need more cases brought on service provision.

FWS goes a long way to clarifying rights related to single sex rights in a lot of cases.

Hicc · 14/05/2026 12:46

usernameinserthere · 14/05/2026 12:43

Case law at present is in respect of employer / employee relationships.

This isn’t relating to general services - but the EHRC guidance is to be issued and will cover some aspects of service provision.

It probably will need more cases brought on service provision.

FWS goes a long way to clarifying rights related to single sex rights in a lot of cases.

Thank you. Lots achieved, but a way to go still.

HenriettaSwanLeavitt · 14/05/2026 12:47

Also worth considering that services are also employers and may be providing facilities that are used by both employees and service users. So I assume the Workplace Regs would still take precedent in this situation?

HenriettaSwanLeavitt · 14/05/2026 12:54

HenriettaSwanLeavitt · 14/05/2026 12:47

Also worth considering that services are also employers and may be providing facilities that are used by both employees and service users. So I assume the Workplace Regs would still take precedent in this situation?

*precedence

MarieDeGournay · 14/05/2026 13:00

I have questions about the 'legality' - compliance with building regs - of taking out blocks of single sex toilets and replace them with an equivalent number of regs-compliant 'universal' toilets.

I wonder if this constitutdes
'the material alteration of a building or a controlled service or fitting'
.
as in
Regulation 3 of the Building Regulations defines ‘building work’.
Building work includes:
a. the erection or extension of a building
b. the provision or extension of a controlled service or fitting
c. the material alteration of a building or a controlled service or fitting.

In which case, where Doc T applies, the alteration would not meet the requirement for single sex provision in the first place, with mixed sex toilets as an optional extra.

Regulation 4 might be relevant too:
If the former provision of single-sex + accessible was adequate for more or less 100% of the population, male, female and able/bodied/disabled, removing that provision and replacing it for the 'convenience' of a very small number of people might contravene
(ii) the building must be no more unsatisfactory in relation to the requirements than before the work was carried out

Opinion polls etc suggest that for the majority of people, removal of the existing single-sex toilets would make the building 'unsatisfactory', but more to the point, it might mean that removing single sex toilets from a building which was already 'satisfactory' made it 'unsatisfactory' in terms of building regs.

IANABRI - I am not a building regs inspector, obviouslySmile but there just seems to be something wrong about taking away an established, perfectly adequate, building-regs-compliant toilet provision to replace it with something that is unpopular, questionably compliant, and also questionable in terms of the total number of toilets provided. And all at the behest of a tiny percentage of the population.

Regulation 4 states that building work should be carried out in such a way that, when work is complete:
a. for new buildings or work on a building that complied with the applicable requirements of the Building Regulations: the building complies with the applicable requirements of the Building Regulations.
b. for work on an existing building that did not comply with the applicable requirements of the Building Regulations:
(i) the work itself must comply with the applicable requirements of the Building Regulations
(ii) the building must be no more unsatisfactory in relation to the requirements than before the work was carried out
The Merged Approved Documents

Justme56 · 14/05/2026 13:20

Hicc · 14/05/2026 10:22

I agree re the importance of this case.

I know it has been touched on before, but what will stop captured organisations from simply making all their toilet provision mixed sex, in the light of this, to avoid having to say no to the men wanting to use the womens? It is my understanding that if single sex facilities are provided, organisations must direct people to use the facility that matches their sex. But organisations don't have to provide single sex facilities do they? They can just have lockable cubicles for everyone?

Obviously there is a cost to this, but I can see some organisations preferring to do this rather than saying no to the trans identified men.

This is what Swift said in the summing up of GLP v EHRC:

In workplaces, it is compulsory to provide sufficient single-sex toilets, as well as sufficient single-sex changing and washing facilities where these facilities are needed. [2] It is not compulsory for services that are open to the public to be provided on single-sex basis or to have single-sex facilities such as toilets. These can be single-sex if it is a proportionate means of achieving a legitimate aim and they meet other conditions in the Act. However, it could be indirect sex discrimination against women if the only provision is mixed-sex.

Seriestwo · 14/05/2026 14:15

All of this will now get lost in the Labour leadership drama which is unfair

BonfireLady · 14/05/2026 14:50

usernameinserthere · 14/05/2026 12:43

Case law at present is in respect of employer / employee relationships.

This isn’t relating to general services - but the EHRC guidance is to be issued and will cover some aspects of service provision.

It probably will need more cases brought on service provision.

FWS goes a long way to clarifying rights related to single sex rights in a lot of cases.

Thank you. Very useful info.

Am I right to assume that case law would be needed in schools as well?

There are two specific types of scenario I'm thinking of:

  1. students sleeping in residential accommodation, including on school trips
  2. staff having access to the following single sex spaces:
  • students' residential accommodation, as above
  • students' changing rooms and toilets

Re 1, the statutory safeguarding guidance that comes into effect in September this year already covers single-sex changing rooms and toilets. Unfortunately, if it stays as per the draft that was shared for consultation, it doesn't provide the same clarity on residential accommodation

Re point 2, to clarify: I'm referring to male staff (who identify as women) entering the female students' spaces.

And as an additional question, have you seen anything in the case law so far that explains how the situation should be handled when a male insists that "I am a girl/woman", and has been accepted as such owing to having ID which says this? E.g. boys and men can get passports which state they are female.

If they apply to work somewhere (or attend a school, as per the school scenarios above), is there anything that employers/schools can do to mitigate their claims about their sex if such documents have been used to be registered on the HR/school system?

WarriorN · 14/05/2026 15:14

usernameinserthere · 14/05/2026 10:18

Updated Draft Letter (for Great Britain / England & Wales)

[Your Full Name]
[Your Job Title]
[Your Department, if applicable]
[Your Contact Details]

[Date]

[Employer’s Name / HR Manager’s Name]
[Company Name]
[Company Address]

Subject: Request for Written Confirmation of Policy on Use of Single-Sex Toilets, Changing Rooms and Showers [EDIT AS APPROPRIATE]

Dear [HR Manager’s Name / Sir or Madam],

I am writing to seek written confirmation of the Company’s policy regarding the use of male and female toilets, changing rooms and showers in our workplace.

Recent case law makes clear that employers can lawfully adopt and apply a policy that female facilities (toilets, changing rooms and showers) are available only to biological women and male facilities only to biological men, and that doing so satisfies the requirements of the Workplace (Health, Safety and Welfare) Regulations 1992.In the High Court case of R (on the application of the Good Law Project and others) v EHRC [2026] EWHC 279 (Admin), Mr Justice Swift held (at paragraph 40):

“If the obligation under regulation 20 is as I have concluded, an employer who provides the lavatories required in the rooms required, and who in good faith adopted and applied a policy that the female lavatories were available only to biological women and the male ones only available to biological men, would do what is required by the Regulations.”

This passage was quoted with approval in the recent Employment Tribunal judgment in LS v NHS England (Case Number: 1802318/2024). In that case, the Tribunal upheld the claimant’s complaint of indirect sex discrimination arising from the employer’s policy of permitting biological males who identify as women to use female toilets, changing rooms and showers.

The Tribunal’s findings confirm that failure to provide and maintain genuine single-sex facilities in accordance with the Workplace Regulations constitutes unlawful discrimination on the grounds of sex. The employer in that case now faces a remedies hearing at which significant damages are expected to be awarded. In LS v NHS England, the Tribunal expressly addressed the common situation where employers rely on external guidance:

“170. [The employer's representative] submitted that the respondent, along with many other employers, was applying the Act as it understood it at that time. [The employer] gave evidence that the respondent relied on the advice of external bodies, including Stonewall, UNISON and other trade unions, in addition to feedback from its staff network. [...]

171. However, reliance on contemporaneous guidance or good practice advice cannot justify an incorrect interpretation of the law. Employers must seek their own legal advice and ensure that they are applying the law correctly.”

In light of this developing case law, I respectfully request that the Company confirm in writing whether it has adopted (or intends to adopt) and will apply a policy that:

Female toilets, changing rooms and showers are designated for and available only to biological women; and

Male toilets, changing rooms and showers are designated for and available only to biological men.

I believe such a clear policy provides certainty and protection for all staff, respects the privacy and dignity of employees (particularly women), and ensures full compliance with the 1992 Regulations and the Equality Act 2010 as interpreted by the courts. I would be grateful to receive this confirmation at your earliest convenience. I am happy to discuss this further if required.

Yours sincerely, [Your Full Name]

This is great, thanks !

MrsOvertonsWindow · 14/05/2026 15:27

BonfireLady · 14/05/2026 14:50

Thank you. Very useful info.

Am I right to assume that case law would be needed in schools as well?

There are two specific types of scenario I'm thinking of:

  1. students sleeping in residential accommodation, including on school trips
  2. staff having access to the following single sex spaces:
  • students' residential accommodation, as above
  • students' changing rooms and toilets

Re 1, the statutory safeguarding guidance that comes into effect in September this year already covers single-sex changing rooms and toilets. Unfortunately, if it stays as per the draft that was shared for consultation, it doesn't provide the same clarity on residential accommodation

Re point 2, to clarify: I'm referring to male staff (who identify as women) entering the female students' spaces.

And as an additional question, have you seen anything in the case law so far that explains how the situation should be handled when a male insists that "I am a girl/woman", and has been accepted as such owing to having ID which says this? E.g. boys and men can get passports which state they are female.

If they apply to work somewhere (or attend a school, as per the school scenarios above), is there anything that employers/schools can do to mitigate their claims about their sex if such documents have been used to be registered on the HR/school system?

That's a good point about adults. Presumably when they drafted the new KCSIE guidance, in particular this:
"Schools and colleges must not allow a child, aged 11 years or older at the start of the school year, to undress in front of a child of the opposite biological sex, to comply with their safeguarding duties"... they didn't think they'd need to add "or creepy adult Fred, now calling himself Freda" who's demanding to "supervise" the girls dormitories and toilets.

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