Cases2306525/2020

Claimant v Hyde Housing Association Limited

28 November 2025Before Employment Judge LumbyCroydonremote video

Outcome

Claimant fails

Individual claims

Direct Discrimination(race)struck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Direct Discrimination(sex)struck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Harassment(race)struck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Harassment(sex)struck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Whistleblowingstruck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Automatic Unfair Dismissalstruck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Unlawful Deduction from Wagesstruck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Holiday Paystruck out

Struck out under Rules 38(1)(b), (c) and (e) due to unreasonable conduct in failing to clarify claims despite repeated tribunal directions, non-compliance with orders, and impossibility of fair trial after five years and ongoing refusal to particularise allegations.

Facts

The claimant brought two claims in September and October 2020 for race and sex harassment, whistleblowing detriment and automatically unfair dismissal. The claims were lengthy and unclear with a very large number of unspecified allegations. Despite repeated tribunal directions over multiple hearings spanning 2021-2024, the claimant failed to clarify the factual and legal allegations even after changing from a lay representative to a solicitor. A previous strike out in October 2021 was overturned on appeal on procedural grounds and the cases remitted. Further directions to clarify the claims by November 2024 were not complied with.

Decision

The tribunal struck out all claims under Rules 38(1)(b), (c) and (e) finding the claimant had conducted proceedings unreasonably by wilfully failing to clarify claims despite repeated clear directions, had not complied with tribunal orders, and that by 2025 (five years after events in 2019-2020) a fair trial was no longer possible given inevitable further delays before any final hearing. The tribunal also refused the claimant's application to reconsider a previous £20,000 costs order.

Practical note

Parties must engage meaningfully with tribunal directions to clarify claims and particularise allegations; persistent refusal to do so over multiple years despite changing representation will result in strike out even in discrimination cases where such orders are normally a last resort.

Legal authorities cited

Bolch v Chipman [2024] IRLR 140Leeks v University College London Hospitals NHS Foundation Trust [2024] EAT 134Emuemukoro v Croma Vigilant (Scotland) Limited [2022] ICR 327

Statutes

Employment Tribunal Procedure Rules 2024 Rule 38(1)(b)Employment Tribunal Procedure Rules 2024 Rule 75Employment Tribunal Procedure Rules 2024 Rule 38(1)(e)Employment Tribunal Procedure Rules 2024 Rule 38(1)(c)

Case details

Case number
2306525/2020
Decision date
28 November 2025
Hearing type
strike out
Hearing days
2
Classification
procedural

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
solicitor