The Court of Appeal in Grant v HM Land Registry held that an employee, Mr Grant, who had disclosed his homosexuality to his colleagues, could not later complain that the disclosure of that information to others constituted direct discrimination or harassment against him. The court noted that Mr Grant had not asked his colleagues to keep his sexuality secret. Further, with regard to the disclosures complained of, the court noted that the tribunal had found that there had been no intention to harass Mr Grant.

The court noted that whilst it was important for people to be able to disclose their sexuality confidentially, once that person had already disclosed that information, it could be treated differently. This is a rather controversial stance to take since many individuals would wish to retain control over the disclosure of their sexual orientation.