Cases2301820/2024

Claimant v London Residential Healthcare Limited

27 November 2025Before Employment Judge D WrightCroydonremote video

Outcome

Claimant fails

Individual claims

Constructive Dismissalnot determined

This was a preliminary hearing focused solely on the disability issue. The constructive dismissal claim was not determined at this hearing.

Unlawful Deduction from Wagesnot determined

This claim for payments related to absences from work was not determined at this preliminary hearing, which focused on the disability question.

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

The tribunal found that the claimant's sensitivity to odours did not constitute a physical or mental impairment under s.6 EqA. The tribunal concluded that a normal aversion to foul odours is not an impairment but rather a proper sensory response, and there was no substantial adverse effect on day-to-day activities. Without a disability, the claimant cannot pursue disability discrimination claims.

Failure to Make Reasonable Adjustments(disability)failed

This claim necessarily failed because the tribunal determined the claimant was not disabled for the purposes of the Equality Act 2010, meaning no duty to make reasonable adjustments arose.

Facts

The claimant worked as a housekeeper in a care home from October 2021 to February 2024. She claimed to have a hypersensitivity to odours causing headaches and gagging. In November 2023, she raised a grievance after being told she could not wear a face mask at work. She produced a GP letter supporting her wearing a mask, but provided no medical records despite being ordered to do so. The respondent argued her reactions were normal responses to foul odours encountered in a care home environment.

Decision

The tribunal determined that the claimant's sensitivity to odours did not constitute a physical or mental impairment under the Equality Act 2010. The judge found that normal aversion to foul smells is a proper sensory function, not an impairment, and there was no substantial adverse effect on day-to-day activities. The claimant therefore was not disabled and could not pursue discrimination claims.

Practical note

A normal sensory response to unpleasant stimuli, even if pronounced, will not constitute a disability without medical evidence of an underlying impairment that substantially affects normal day-to-day activities.

Legal authorities cited

Statutes

Equality Act 2010 s.6Equality Act 2010 Schedule 1

Case details

Case number
2301820/2024
Decision date
27 November 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Housekeeper
Service
2 years

Claimant representation

Represented
No