Cases2200486/2024

Claimant v Voiceability Advocacy

28 November 2025Before Employment Judge T.R. SmithLondon Centralin person

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Claim struck out under Rule 38(1)(e) because it was no longer possible to have a fair hearing within a reasonable timeframe. The next available tribunal listing was not before August 2027. Key witnesses (the decision maker Ms Duke and appeal officer Mr Breckell) had left the respondent and were unlikely to be available, causing severe prejudice to both parties.

Discrimination Arising from Disability (s.15)(disability)struck out

Claim for unfavourable treatment arising from disability struck out under Rule 38(1)(e) for the same reasons as the unfair dismissal claim: no fair hearing possible within a reasonable time given the August 2027 listing, unavailability of key witnesses, and uncertainty over the claimant's fitness to participate despite her attendance at this preliminary hearing.

Failure to Make Reasonable Adjustments(disability)struck out

Claim struck out under Rule 38(1)(e) on the basis that a fair hearing was no longer possible within a reasonable timeframe. The tribunal found that witness evidence was of real importance to a fair determination, and key witnesses had left and were unlikely to be available in August 2027. The claimant's fitness to participate remained uncertain despite medical evidence.

Harassment(disability)struck out

Harassment related to disability claim struck out under Rule 38(1)(e) because it was no longer possible to have a fair hearing within a reasonable time. The tribunal balanced the severe prejudice to both parties and concluded that the only proportionate response was to strike out the claims given the unavailability of key witnesses and the next available listing not being before August 2027.

Unlawful Deduction from Wageswithdrawn

Withdrawn by claimant during the hearing and dismissed upon withdrawal under Rule 51.

Holiday Paywithdrawn

Withdrawn by claimant during the hearing and dismissed upon withdrawal under Rule 51.

Facts

The claimant was dismissed by reason of redundancy on 30 November 2023 from her role with the respondent charity. She brought claims of unfair dismissal and disability discrimination (unfavourable treatment, failure to make reasonable adjustments, and harassment). The full merits hearing listed for January 2025 was postponed on the day at the claimant's request due to ill health. The claimant had been diagnosed with PTSD and severe persistent depression. A preliminary hearing to consider strike-out was listed but also postponed due to the claimant's health. The respondent applied to strike out the claims on the basis that a fair hearing was no longer possible within a reasonable time.

Decision

The tribunal struck out all claims under Rule 38(1)(e) finding it was no longer possible to have a fair hearing within a reasonable timeframe. The next available listing was August 2027. Key witnesses including the dismissing officer (Ms Duke) and appeal officer (Mr Breckell) had left the respondent and were unlikely to be available. The tribunal balanced the severe prejudice to both parties and concluded that witness evidence was of real importance to a fair determination, and that strike-out was the only proportionate response despite being draconian.

Practical note

Even in disability discrimination cases where strike-out must be approached with caution, tribunals will strike out claims where key witnesses have departed and the next available listing causes such delay that a fair hearing is impossible, particularly where the claimant's fitness to participate remains uncertain andmedically unproven despite some limited engagement.

Legal authorities cited

Blockbuster Entertainment Ltd v James [2006] EWCA Civ 684

Statutes

Article 6 European Convention on Human RightsEmployment Tribunal Procedure Rules 2024 Rule 51Employment Tribunal Procedure Rules 2024 Rule 38

Case details

Case number
2200486/2024
Decision date
28 November 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
charity
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No