Cases2404345/2024

Claimant v Counterline Limited

23 September 2025Before Employment Judge JohnsonLiverpoolon papers

Outcome

Claimant fails

Individual claims

Constructive Dismissalstruck out

The claim was struck out under Rule 38(1)(d) for failure to actively pursue. The claimant was imprisoned and, despite being represented by his father as lay representative, took no meaningful steps to progress the claim over many months, causing inordinate and inexcusable delay and serious prejudice to the respondent.

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

The claim was struck out under Rule 38(1)(d) for failure to actively pursue. The claimant did not provide medical evidence of disability (carpal tunnel syndrome) and failed to pursue the claim while in custody.

Redundancy Paystruck out

The claim was struck out under Rule 38(1)(d) for failure to actively pursue. The claimant resigned before the redundancy process began but took no steps to progress this claim while imprisoned.

Breach of Contractstruck out

The claim was struck out under Rule 38(1)(d) for failure to actively pursue due to inordinate and inexcusable delay caused by the claimant's failure to progress the case while in prison.

Holiday Paystruck out

The claim was struck out under Rule 38(1)(d) for failure to actively pursue. No progress was made on this element of the claim after the initial filing.

Unlawful Deduction from Wagesstruck out

The claim was struck out under Rule 38(1)(d) for failure to actively pursue. The claimant failed to take any meaningful steps to advance this claim while imprisoned.

Facts

The claimant worked as a forklift truck driver from May 2019 until his resignation on 9 July 2024. He filed multiple claims including constructive dismissal, disability discrimination (carpal tunnel syndrome), and various wage-related claims. Shortly after filing, the claimant was imprisoned and represented by his father as lay representative. Between December 2024 and September 2025, no meaningful progress was made on the claim despite multiple case management hearings and tribunal directions. The claimant's father argued that nothing could happen until the claimant's release, estimated at July 2026 at the earliest.

Decision

The tribunal struck out all claims under Rule 38(1)(d) for failure to actively pursue. The judge found inordinate and inexcusable delay, noting that despite being in prison, the claimant and his father made no meaningful attempt to progress the case, explore what participation was possible from custody, or provide evidence of limitations. This caused serious prejudice to the respondent who had been waiting since August 2024 with no prospect of resolution until mid-2026 or later.

Practical note

A claimant's imprisonment does not automatically excuse inactivity in tribunal proceedings; even with limited access, claimants must take proactive steps to explore what participation is possible and to progress claims, or risk strike-out for failure to actively pursue.

Legal authorities cited

Khan v London Borough of Brent UKEAT/0002/18Leeks v University College London Hospitals NHS Foundation Trust [2024] EAT 134Birkett v James [1978] AC 297Evans Executors v Metropolitan Police Authority [1992] IRLR 570Rolls Royce v Riddle [2008] IRLR 873

Statutes

Employment Tribunal Procedure Rules 2013 Rule 37(1)(d)Employment Tribunal Procedure Rules 2024 Rule 38(1)(d)

Case details

Case number
2404345/2024
Decision date
23 September 2025
Hearing type
strike out
Hearing days
Classification
procedural

Respondent

Sector
manufacturing
Represented
No
Rep type
self

Employment details

Role
fork lift truck driver
Service
5 years

Claimant representation

Represented
No