Cases6011292/2024

Claimant v HSBC Group Management Services Limited

11 December 2025Before Employment Judge Andrew Clarke KCBirminghamremote video

Outcome

Other

Individual claims

Direct Discrimination(pregnancy)not determined

This was a preliminary hearing on time limits and amendment applications only. The substantive claims of pregnancy and maternity discrimination contrary to ss.18(2), 18(4) and 41 EqA 2010 have not yet been determined on their merits.

Direct Discrimination(pregnancy)not determined

Substantive claims relating to maternity leave discrimination have not yet been determined. The tribunal ruled only that the claims were not to be struck out for being out of time and that claimant had reasonable prospect of showing extension of time was just and equitable.

Facts

Claimant, a Chartered Occupational Psychologist, worked as contractor for R1 via umbrella company R3 from December 2021. She announced pregnancy in October 2023 whilst applying for permanent role. After series of rejections and non-extensions, her engagement ended 29 March 2024, shortly after she began maternity leave on 7 February 2024 and gave birth on 9 February 2024. She did not present ET1 until 10 September 2024, nearly 2½ months outside primary time limit. She applied to amend claim in November 2025 to add allegations concerning later role in Dubai.

Decision

Tribunal refused R1's applications to strike out claims or make deposit orders on time limit grounds, finding claimant had reasonable prospect of showing just and equitable extension based on combination of factors: late discovery of material facts, complications in pregnancy and post-birth recovery, caring for sick child, mental health difficulties, and desire not to prejudice work prospects. Tribunal granted amendment to add one allegation (rejection for Dubai role) but refused another (negative reference), primarily due to forensic prejudice and speculative nature of latter claim.

Practical note

Combination of pregnancy complications, post-birth caring responsibilities, mental health difficulties, and late discovery of facts may together provide basis for just and equitable extension even where each factor alone might be insufficient, particularly where delay has not caused severe evidential prejudice.

Legal authorities cited

Anyanwu v South Bank Student Union [2001] ICR 391Mechkarov v Citibank NA [2016] ICR 1121Hemdan v Ishmail [2017] IRLR 228Chief Constable of Lincolnshire Police v Caston [2009] EWCA Civ 1298Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23HSBC Bank plc v Chevalier-Firescu [2025] IRLR 268Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] ICR 1194Jones v Secretary of State for Health [2025] ICR 738Barnes v Commissioner of Police for the Metropolis UKEAT/0474/05Miller v MoJ UKEAT/0003/15Selkent Bus Co Ltd v Moore [1996] IRLR 661Vaughan v Modality Partnership [2021] ICR 535Chandhok v Tirkey [2015] ICR 527Gillett v Bridge 86 Ltd UKEAT/0051/17Rathakrishnan v Pizza Express [2016] ICR 283

Statutes

ET Procedure Rules 2024 r.40Equality Act 2010 s.18(4)Equality Act 2010 s.18(2)Equality Act 2010 s.41Equality Act 2010 s.109Equality Act 2010 s.110(1)Equality Act 2010 s.123Equality Act 2010 s.136ET Procedure Rules 2024 r.38

Case details

Case number
6011292/2024
Decision date
11 December 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Role
Assessment SME
Service
2 years

Claimant representation

Represented
Yes
Rep type
barrister