Cases3309200/2024

Claimant v Kier Limited

6 November 2025Before Employment Judge L CowenWatfordin person

Outcome

Partly successful

Individual claims

Direct Discrimination(disability)struck out

Struck out for failure to comply with tribunal orders and having no reasonable prospect of success. Despite multiple case management hearings and written orders, the claimant was unable to articulate specific acts of disability discrimination or explain the link between her disability and the alleged acts.

Failure to Make Reasonable Adjustments(disability)not determined

Claim remains live but claimant struggled to identify the PCP relied upon. Tribunal allowed limited particularisation of four reasonable adjustments sought but case management issues remain unresolved.

Direct Discrimination(race)not determined

Direct race discrimination claim remains unparticularised but has not been struck out at this stage. Claimant unable to show nexus between treatment and race.

Harassment(race)not determined

Harassment claim partially identified (reference to 'spice girls' comment acknowledged) but claimant remained vague on other allegations. Claim proceeding to case management.

Victimisationnot determined

Claimant failed to identify the protected act relied upon and failed to particularise the detriment suffered, but claim not struck out at this stage.

Unfair Dismissalnot determined

Claim identified and particularised in case management hearing on 1 July 2025 and allowed to proceed to final hearing.

Automatic Unfair Dismissalnot determined

S.103A ERA automatic unfair dismissal claim for protected disclosure identified and particularised, allowed to proceed to case management and final hearing.

Detrimentnot determined

S.47B ERA detriment from whistleblowing claim identified and particularised in case management, allowed to proceed to final hearing.

Breach of Contractnot determined

Claimant failed to identify specific contractual term breached or detriment resulting from breach, but claim not struck out at this stage.

Unlawful Deduction from Wagesnot determined

Arrears of pay claim brought in first ET1 form (3309200/2024) but not further particularised in judgment.

Facts

The claimant brought two consolidated claims alleging race and disability discrimination, reasonable adjustments, arrears of pay, unfair dismissal and whistleblowing. Despite four case management hearings and multiple orders requiring her to particularise her claims, she was unable to articulate the legal basis of several claims, particularly direct disability discrimination. The tribunal attempted to extract details both in writing and verbally but the claimant could not provide coherent explanations of the specific allegations, PCPs, or legal elements required.

Decision

The tribunal struck out the direct disability discrimination claim for failure to comply with orders and having no reasonable prospect of success. The tribunal also barred the claimant from bringing any further amendments or additional claims. The remaining particularised claims (unfair dismissal, automatic unfair dismissal for whistleblowing, detriment from whistleblowing, and failure to make reasonable adjustments) were allowed to proceed to case management and final hearing.

Practical note

Even unrepresented claimants must be able to articulate the legal basis of their claims after reasonable assistance; tribunals will reluctantly strike out claims where repeated attempts to obtain particularisation fail and further indulgence would be disproportionate and prevent a fair hearing.

Legal authorities cited

A v B [2011] ICR D9Forrest v Amazon Web Services EMEA SARL UK Branch [2025] IRLR 656Harris v Academies Enterprise Trust [2015] ICR 617Weir Valves and Controls (UK) Ltd v Armitage [2004] ICR 371Blockbuster Entertainment Ltd v James [2006] IRLR 630Abertawe Bro Morgannwg University Health Board v Ferguson [2013] ICR 1108Anyanwu v South Bank Student Union [2001] ICR 391

Statutes

Employment Tribunal Rules 2024 Rule 38Employment Rights Act 1996 s.47BEmployment Rights Act 1996 s.103AEmployment Rights Act 1996 s.98Employment Tribunal Rules 2024 Rule 6(2)

Case details

Case number
3309200/2024
Decision date
6 November 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
construction
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No