In Insitu Cleaning Co Ltd and another v Heads the EAT rejects an employer's argument that a single act cannot amount to sexual harassment until it has been done and rejected as "unwanted conduct".
In Insitu Cleaning Co Ltd v Heads (1 September 1994) EOR59B, the EAT rules that a remark about a woman's breasts subjected her to a detriment and was unlawfully discriminatory. The EAT recommends that the employers adopt a sexual harassment procedure to prevent future incidents.