Cases4106415/2024

Claimant v Scottish Police Authority

22 September 2025Before Employment Judge L MurphyScotlandin person

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that while the claimant was disabled and the respondent had knowledge of this, the adjustments contended for were not objectively reasonable. The main adjustment sought - instructing 12 named individuals to restrict contact with the claimant - would have been unfair to those individuals, risked breaching confidentiality, and potentially conflicted with a prior COT3 settlement. The tribunal concluded that without this key adjustment, which was found unreasonable, the other adjustments would not have enabled a return to work, so there was no duty to make them.

Facts

The claimant, a part-time Senior Scene Examiner employed since 2018, had previously settled a 2020 sex discrimination and harassment claim via COT3 against six colleagues. She suffered from anxiety and depression and was largely absent from work from April 2022 onwards due to sick leave and maternity leave. She raised grievances in 2023 and December 2023 about various managers. From February 2024 she remained off sick. An occupational health report recommended various adjustments including restricting contact with managers from the 2020 case. The claimant sought extensive adjustments including instructions to 12 named individuals to minimize contact with her.

Decision

The tribunal dismissed the claim for failure to make reasonable adjustments. While accepting the claimant was disabled and the respondent had knowledge of this, the tribunal found the main adjustment sought - instructing 12 individuals to restrict contact - was not objectively reasonable. It would be unfair to those individuals, create confidentiality issues, and sit uneasily with the prior COT3 settlement. Without this key adjustment, the other adjustments would not enable a return to work, so there was no duty to make them.

Practical note

An adjustment requiring restrictions on multiple employees' contact with a disabled colleague may not be reasonable where it would unfairly affect those employees, create confidentiality difficulties, and potentially conflict with a prior settlement agreement, especially where the adjustment would not in any event enable a return to work.

Legal authorities cited

Johnson v Nottinghamshire Combined Police Authority [2003] ICR 1444Roberts v Governing Body of Whitecross SchoolCarrera v United First Partners ResearchMeikle v Nottinghamshire County Council [2004] IRLR 703Archibald v Fife Council [2004] SLT 942Home Office v Collins [2005] EWCA 598NCH Scotland v McHugh [2006] UKEATS/0010/06/MTLondon Underground Ltd v Vuoto [2010] UKEAT/0123/09/DADoran v DWP [2014] UKEATS/0017/14G4S Securitas v PowellHill v Lloyds Bank PlcSmith v Churchills Stairlifts plc [2006] ICR 524

Statutes

Equality Act 2010 Schedule 8Equality Act 2010 s.26Equality Act 2010 s.20Equality Act 2010 s.6

Case details

Case number
4106415/2024
Decision date
22 September 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
solicitor

Employment details

Role
Senior Scene Examiner

Claimant representation

Represented
Yes
Rep type
solicitor