Cases2306571/2023

Claimant v South London and Maudsley NHS Foundation Trust

22 September 2025Before Employment Judge SudraLondon Southremote video

Outcome

Partly successful

Individual claims

Unfair Dismissalnot determined

This claim will proceed to a Final Hearing on 26th and 27th August 2025. The tribunal has not yet determined the merits of the unfair dismissal complaint.

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

The tribunal found that the Claimant did not meet the statutory test for disability at any relevant time. The Claimant failed to prove that her right shoulder pain had a substantial and long-term adverse effect on normal day-to-day activities during the relevant period (13 September 2022 to 18 June 2023). Medical evidence did not corroborate the Claimant's assertions about impact on daily activities such as driving, cooking, shopping and bathing. The claim was struck out as having no reasonable prospects of success under Rule 38(1)(a).

Failure to Make Reasonable Adjustments(disability)struck out

The tribunal found that the Claimant did not meet the statutory test for disability at any relevant time. Because the Claimant was not disabled within the meaning of the Equality Act 2010, she could not pursue a claim for failure to make reasonable adjustments. The claim was struck out as having no reasonable prospects of success under Rule 38(1)(a).

Facts

The Claimant was employed as a healthcare assistant by an NHS Mental Health Trust from December 2000 until her dismissal on capability grounds on 18 June 2023. She claimed to be disabled due to chronic right shoulder pain, first reported in February 2014 following a road traffic incident. She had surgery in late 2020/early 2021 and was reported as 'significantly better' and 'back to activities such as driving and performing all activities of daily living' by May 2021. She did not return to her GP for shoulder pain between May 2021 and January 2024. The relevant period for assessing disability was 13 September 2022 to 18 June 2023.

Decision

The tribunal found that the Claimant was not disabled within the meaning of the Equality Act 2010 during the relevant period. While she had a right shoulder impairment, the medical evidence did not support her assertion that it had a substantial and long-term adverse effect on normal day-to-day activities. The disability discrimination claims (discrimination arising from disability and failure to make reasonable adjustments) were struck out as having no reasonable prospects of success. The unfair dismissal claim will proceed to a Final Hearing.

Practical note

Claimants must provide credible medical evidence to substantiate disability claims; self-reported difficulties in a disability impact statement will not suffice where medical records contradict or fail to support the alleged substantial and long-term adverse effects on day-to-day activities.

Legal authorities cited

Cruickshank v VAW Motorcast Ltd [2002] ICR 729Hendricks v Metropolitan Police Commissioner [2003] ICR 530McDougall v Richmond Adult Community College [2008] EWCA Civ 4Goodwin v Patent Office [1999] ICR 302

Statutes

Equality Act 2010 Schedule 1 Part 1Equality Act 2010 s.6Equality Act 2010 s.212(1)

Case details

Case number
2306571/2023
Decision date
22 September 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
solicitor

Employment details

Role
health care assistant
Service
23 years

Claimant representation

Represented
Yes
Rep type
lay rep