Cases3305039/2024

Claimant v Funeral Services Limited t/a Co-Op Funeralcare

16 December 2025Before Employment Judge M WarrenNorwichremote video

Outcome

Claimant fails

Individual claims

Discrimination Arising from Disability (s.15)(disability)failed

The tribunal found that the claimant did not meet the definition of a disabled person under the Equality Act 2010 at the material time. Although he suffered from mixed anxiety and depressive disorder from August to December 2023, the substantial adverse impact lasted only approximately five months. There was insufficient medical evidence to establish that the condition was likely to last 12 months or recur at the material time. The tribunal emphasised the absence of medical evidence beyond GP records and the lack of a narrative medical report to support the claim that the impairment was long-term.

Unfair Dismissalnot determined

This claim was not determined at this preliminary hearing, which was solely concerned with disability status. The case remains listed for final hearing in March 2026.

Facts

Mr Hughes worked for the respondent from May 2009 to February 2024, resigning after nearly 15 years. During 2023, he experienced multiple stressful life events: caring for his terminally ill mother, relationship breakdown, distressing holiday events, and workplace stress. He was diagnosed with mixed anxiety and depressive disorder in October 2023 and prescribed Citalopram. Medical records indicate the condition lasted from October to December 2023 (approximately 3 months). He stopped taking medication after leaving employment in February 2024. The tribunal heard evidence about his mental health symptoms and their impact, including a GAD-7 score of 19 (severe anxiety) in August 2023.

Decision

The tribunal dismissed the disability discrimination claim because Mr Hughes did not meet the definition of a disabled person under the Equality Act 2010 at the material time. While the judge accepted he suffered from mixed anxiety and depressive disorder with substantial adverse effects between approximately August and December 2023, this period was only about five months. Critically, there was insufficient medical evidence to establish that the condition was likely to last 12 months or recur at the relevant time. The judge noted the absence of expert medical evidence beyond basic GP records and emphasised that the burden of proof lay with the claimant.

Practical note

Even with genuine mental health difficulties requiring medication, disability status requires robust medical evidence proving the condition was likely to last 12 months or recur at the material time — GP records and impact statements alone may be insufficient without expert opinion.

Legal authorities cited

Swift v Chief Constable of Wiltshire Constabulary [2004] ICR 909 EATAll Answers Ltd v W [2021] EWCA Civ 606Ahmed v Metroline Travel Ltd UKEAT/0400/10Woodrup v London Borough of Southwark [2003] IRLR 111 CATesco Stores Ltd v Tennant UKEAT0167/19Goodwin v Patent Office [1999] ICR 302Leonard v Southern Derbyshire Chamber of Commerce [2001] IRLR 19Richmond Adult Community College v McDougall [2008] ICR 431 CAJ v DLA Piper UK LLP [2010] ICR 1052SCA Packaging Ltd v Boyle [2009] ICR 1056 HL

Statutes

Equality Act 2010 Schedule 1 para 12Equality Act 2010 Schedule 1 para 5Equality Act 2010 Schedule 1 para 2Equality Act 2010 s.212Equality Act 2010 s.6

Case details

Case number
3305039/2024
Decision date
16 December 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
solicitor

Employment details

Service
15 years

Claimant representation

Represented
Yes
Rep type
solicitor