legislation in accordance with Directives would not be effective or sensible because of the need for clarity, certainty and comprehensibility. Section 4A(1)(a) should be recast so as to eliminate the issue of causation, R. (on the application of Amicus) v. Secretary of State for Trade and Industry [2004] EWHC 860 (Admin), [2007] I.C.R. 1176 considered. (2) There could be harassment of a woman if the effect of denigratory conduct, directed towards another party, not necessarily a woman, related to sex, but not of a sexual nature, had the effect of creating a humiliating or offensive environment for her. The new s. 4A(1) would have to be read down to produce that result and accordingly should be amended. (3) Under the law of discrimination prior to the introduction of s. 4A of the Act the test was properly to be regarded as objective, Driskel v. Peninsula Business Services Ltd [2000] IRLR 151 EAT applied. Therefore, no issue of regression arose. (4) So long as s. 4A was framed in terms of unwanted conduct engaged in "on the ground of her sex" by the employer, it was difficult, if not impossible, to see how an employer could be held liable for knowing failure to take steps to prevent harassment by third parties that created an offensive working environment for employees. Section 4A(1) should be recast to allow for such a claim. (5) Section 3A should be recast so as to eliminate the statutory requirement for a comparator who was not pregnant or who was not on maternity leave. (6) Section 6A should be recast so as to provide that discrimination claims that had previously been available should not be excluded, Lewen v Denda (C333/97) [2000] All E.R. (EC) 261 ECJ (6th Chamber) and Land Brandenburg v. Sass (C-284/02) [2004] ECR. I-11143 ECJ (1st Chamber) applied. See also Gender equality Human Rights Act 1998 List of gender equality lawsuits UK employment discrimination law UK labour law Notes 2007 in case law 2007 in British law Anti-discrimination law in the United Kingdom High Court of Justice cases Parental leave in the United Kingdom United Kingdom administrative case law United Kingdom labour case law