Cases4106855/2024

Claimant v Viewpoint Housing Association Ltd

22 December 2025Before Employment Judge Porter SIRScotlandremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Tribunal found it was reasonably practicable for claimant to have submitted ET1 on time. Claimant had advice from CAB and Acas in late September 2024 to raise proceedings urgently, but did not file until 17 October 2024. Claimant's evidence of ill health preventing filing was unsupported by medical evidence. Claim dismissed as tribunal lacked jurisdiction under s.111 ERA 1996.

Direct Discrimination(race)struck out

Tribunal declined to extend time under just and equitable test (s.123(1)(b) Equality Act 2010). Although delay of 17 days was relatively short and no prejudice to respondent shown, claimant provided no cogent reason for delay. Claimant had advice from CAB and Acas by late September 2024 but did not file until 17 October 2024, with no medical evidence supporting claimed ill health. Tribunal applied Robertson v Bexley: extension of time is exception not the rule.

Facts

Claimant was dismissed for gross misconduct on 21 May 2024 after 9 years' service as a care assistant. She was represented at the disciplinary hearing by Unison official Greig Kelbie, who did not advise her of tribunal rights. She contacted Acas on 18 July 2024 and received an EC certificate on 29 August 2024. In late September 2024 she received advice from CAB and Acas to submit a claim urgently due to imminent time limit expiry. Her ET1 was submitted on 17 October 2024, 17 days out of time. The last timely filing date was 1 October 2024.

Decision

The tribunal dismissed both claims as time-barred. For unfair dismissal, it found it was reasonably practicable to submit on time, noting claimant had advice from CAB and Acas by late September but failed to file until 17 October without medical evidence of incapacity. For race discrimination, the tribunal declined to extend time on just and equitable grounds, finding no cogent explanation for the 17-day delay despite timely advice, applying the principle that extension of time is the exception not the rule.

Practical note

Lack of advice from a trade union representative at the time of dismissal does not excuse late filing where claimant subsequently receives clear advice on time limits from Acas or CAB but still fails to act promptly without medical evidence of incapacity.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336Porter v Bandridge Ltd [1978] ICR 943King v Gemalto UK Ltd 2022 EAT 29Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] ICR 1194Robertson v Bexley Community Centre t/a Leisure Link [2003] IRLR 434Southwark London Borough Council v Afolabi [2003] ICR 800Midland Bank plc v Samuels EAT 672/92Trevelyans (Birmingham) Ltd v Norton [1991] ICR 433

Statutes

ERA 1996 s.111Equality Act 2010 s.123(1)(b)

Case details

Case number
4106855/2024
Decision date
22 December 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
charity
Represented
Yes
Rep type
solicitor

Employment details

Role
care assistant
Service
9 years

Claimant representation

Represented
No