Cases6005798/2025

Claimant v NG Bailey Group Limited

21 October 2025Before Employment Judge GreerManchesterremote video

Outcome

Other

Individual claims

Discrimination Arising from Disability (s.15)(disability)not determined

Preliminary hearing dealt only with time limit issue. Tribunal found it just and equitable to extend time, allowing the discrimination claim to proceed. The claim relates to alleged consideration of the claimant's mental health in the redundancy decision. Substantive merits have not yet been determined.

Facts

The claimant was dismissed by reason of redundancy on 4 September 2024 after nearly two years' service as a Business Performance Practitioner. He had suffered a mental health crisis in June-July 2024. Following a DSAR submitted in December 2024, the claimant received internal emails on 15 January 2025 that suggested his mental health and short service were factors in the redundancy decision. He contacted ACAS on 2 February 2025 and filed his claim on 20 February 2025, 98 days after the limitation deadline.

Decision

The tribunal found it just and equitable to extend time by 98 days. Although the delay was substantial, the claimant could not reasonably have known the factual basis for his discrimination claim until receiving the DSAR response after the limitation period had expired. He acted promptly thereafter (36 days), his mental health affected his ability to formulate the claim, forensic prejudice to the respondent was limited, and the claim had arguable merit. The discrimination complaint will proceed.

Practical note

A substantial delay beyond the limitation period may still be excused where key evidence emerges post-deadline via DSAR, the claimant acts promptly thereafter, mental health impacts capacity, and forensic prejudice is minimal.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336Director of Public Prosecutions v Marshall 1998 ICR 518Pathan v South London Islamic Centre EAT 0312/13Concentrix CVG Intelligent Contact Ltd v Obi [2022] EAT 149Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Bexley Community Centre (t/a Leisure Link) v Robertson [2003] EWCA Civ 576Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] EWCA Civ 640Owen v Network Rail Infrastructure Limited [2023] EAT 106Chief Constable of Lincolnshire Police v Caston [2010] IRLR 327Miller v Ministry of Justice EAT 0003/15HSBC Bank plc v Chevalier-Firescu [2025] ICR D7Jones v Secretary of State for Health and Social Care [2024] EWCA Civ 1568Alum v Thames Reach Charity [2022] EAT 8Kumari v Greater Manchester Mental Health NHS Foundation Trust [2022] EAT 132Secretary of State for Justice v Johnson [2022] EAT 1

Statutes

Limitation Act 1980 s.33Equality Act 2010 s.207BEquality Act 2010 s.140BEquality Act 2010 s.13Equality Act 2010 s.123

Case details

Case number
6005798/2025
Decision date
21 October 2025
Hearing type
preliminary
Hearing days
0.5
Classification
contested

Respondent

Sector
construction
Represented
Yes
Rep type
solicitor

Employment details

Role
Business Performance Practitioner
Service
2 years

Claimant representation

Represented
No