The EAT has held that the marriage discrimination provisions of the Sex Discrimination Act 1975 protected a woman against less favourable treatment on the ground that she was married to a particular man. It followed that a tribunal had erred in rejecting an employee's direct marriage discrimination claim on the basis that the treatment complained of was not on the ground that she was married per se, but on the ground of her relationship with her husband.

Since 1 October 2010, the marriage (and civil partnership) discrimination provisions of the repealed SDA 1975 have been reflected in the Equality Act 2010. Although the wording is slightly different, the EAT's decision in this case is relevant to the current law. (Dunn v Institute of Cemetery and Crematorium Management UKEAT/0531/10.)