Cases6013763/2025

Claimant v Secretary of State for Work and Pensions

16 December 2025Before Employment Judge J. Galbraith-MartenLondon Centralremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Claimant had only 14 months' continuous service and did not meet the two years' continuous service requirement under s.108 Employment Rights Act 1996. Claim struck out as having no reasonable prospect of success.

Direct Discrimination(sex)struck out

Tribunal found claimant could not establish a prima facie case of sex discrimination. The matters relied on related to the reasonableness of dismissal, not the mind of the decision maker. There was no evidence or information suggesting the respondent treated him differently because of his sex. Claim struck out as having no reasonable prospect of success.

Wrongful Dismissalstruck out

Claimant's application to amend to add wrongful dismissal claim was refused. The claim was a new cause of action first raised on 13 July 2025, over 6 months after dismissal on 14 January 2025, and thus out of time. Tribunal found it was reasonably practicable for claim to have been presented in time or by 25 May 2025, and did not extend time.

Facts

The claimant was employed by the Department for Work and Pensions as an executive work coach at Acton job centre from 13 November 2023 to 14 January 2025. He was summarily dismissed for gross misconduct after a female customer complained about his behaviour towards her. Following an investigation, the respondent substantiated the allegations, which related to inappropriate contact and cultivating a relationship with the customer, including engaging with her on social media. The claimant brought claims for unfair dismissal and sex discrimination, and subsequently sought to amend his claim to add wrongful dismissal.

Decision

The tribunal refused the amendment to add wrongful dismissal as it was a new claim presented out of time with no reasonable practicability explanation. The unfair dismissal claim was struck out because the claimant had only 14 months' service and did not meet the two-year qualifying period. The sex discrimination claim was struck out as having no reasonable prospect of success because the claimant could not establish a prima facie case—his complaints related to the reasonableness of his dismissal rather than providing evidence his sex was a factor in the decision.

Practical note

Litigants in person must understand the distinction between different causes of action and time limits; complaints about procedural unfairness in dismissal do not, without more, establish a prima facie case of discrimination based on a protected characteristic.

Legal authorities cited

Efobi v Royal Mail Group Ltd [2021] UKSC 33Ahmed v Amnesty International [2009] ICR 1450Chapman v Simon [1994] IRLR 124, CAHewage v Grampian Health Board [2012] UKSC 37Martin v Devonshires Solicitors [2011] ICR 352Shamoon v Chief Constable of the Royal Ulster Constabulary [2003] ICR 337Nagarajan v London Regional Transport [2000] 1 AC 501Igen v Wong [2005] ICR 931Madarassy v Nomura International Plc [2007] ICR 867Hasan v Tesco Stores Ltd EAT0098/16Mbuisa v Cygnet Healthcare Ltd EAT 119/18Anyanwu and anor v South Bank Student Union and another [2001] ICR 391, HLBalls v Downham Market High School and Colleges [2011] IRLR 217, EATCox v Adecco Group Uk & Ireland and ors [2021] ICR 1307, EATSelkent Bus Company Ltd v Moore [1996] ICR 836

Statutes

Equality Act 2010 s.23Equality Act 2010 s.136Employment Tribunal Procedure Rules 2024 Rule 38(1)(a)Employment Tribunal Extension of Jurisdiction (England & Wales) Order 1994Employment Rights Act 1996 s.108Equality Act 2010 s.13

Case details

Case number
6013763/2025
Decision date
16 December 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
central government
Represented
Yes
Rep type
barrister

Employment details

Role
Executive Work Coach
Service
1 years

Claimant representation

Represented
No