Cases2219585/2024

Claimant v Mitie Limited

22 September 2025Before Employment Judge EmeryLondon Centralremote video

Outcome

Claimant succeeds

Individual claims

Unfair Dismissalsucceeded

The tribunal found the respondent failed to obtain an up-to-date Occupational Health report before dismissing, despite clear medical evidence (Med3 dated 4 December 2023) suggesting the claimant could return to work with adjustments in the foreseeable future. This was outside the range of reasonable responses. The respondent also failed to follow its own Absence policy requiring an OH report at stage 2. At appeal, material inaccuracies in notes and failure to let claimant check them before decision took the appeal decision outside the range of reasonable responses.

Discrimination Arising from Disability (s.15)(disability)succeeded

The tribunal accepted the respondent's legitimate aim of running its business efficiently, but found dismissal was not a proportionate means of achieving that aim. The respondent failed to consider adjustments explicitly raised in the Med3 and failed to commission an OH report that would likely have provided a return-to-work date and recommended adjustments. The length of absence alone was not enough to justify dismissal given the medical evidence showing prospect of return with adjustments.

Failure to Make Reasonable Adjustments(disability)succeeded

The respondent had a PCP requiring security officers to be relatively fit and stand for prolonged periods, which put the claimant at a substantial disadvantage. The tribunal found adjustments such as transfer to a sedentary role (e.g. CCTV operative), phased return, adjusted shift patterns had a real prospect of enabling the claimant's return to work by June 2024. The respondent failed to refer the claimant to OH to properly explore these adjustments, despite medical evidence (Med3 and surgeon's letter) suggesting adjustments could enable return. The respondent unreasonably failed to consider these adjustments before dismissing.

Facts

The claimant, a security officer with 17.5 years' service, was off work continuously from September 2021 to January 2024 due to arthritis requiring bilateral knee replacements. His left knee replacement went well, but the right knee (operated April 2022) had complications and slower recovery. By December 2023, his surgeon's Med3 stated he was 'not fit to work' but 'may benefit from workplace adaptations' and 'may be able to undertake amended duties'. The surgeon's contemporaneous letter to the GP noted the claimant was continuing to improve and recommended amended duties/workplace changes as he could not be on his feet all day. The respondent dismissed him on 4 January 2024 for long-term incapability without obtaining an updated Occupational Health report, despite HR repeatedly suggesting one. The claimant's appeal was dismissed in May 2024, again without seeking OH advice, and based in part on inaccurate meeting notes the claimant was not given opportunity to correct.

Decision

The tribunal found the dismissal was unfair because it was outside the range of reasonable responses to dismiss without obtaining an up-to-date OH report when medical evidence (the Med3 and surgeon's letter) suggested the claimant could return with adjustments in the foreseeable future. The tribunal also found discrimination arising from disability (dismissal was not a proportionate means of achieving the legitimate aim) and failure to make reasonable adjustments (transfer to sedentary role such as CCTV operator, phased return, adjusted shifts) which had a real prospect of enabling return by June 2024. The respondent unreasonably failed to explore these despite clear medical evidence and repeated HR prompts.

Practical note

Employers must obtain up-to-date medical evidence, particularly Occupational Health reports, before dismissing for long-term sickness absence when there is evidence suggesting possible return with adjustments, even after a lengthy absence — internal HR advice to do so should not be ignored.

Legal authorities cited

Griffiths v Secretary of State for Work and Pensions [2017] ICR 160Royal Bank of Scotland v Ashton [2011] ICR 632Smith v Churchills Stairlifts plc [2005] EWCA 1220Jennings v Barts and the London NHS Trust [2013] EAT EqLR 326Garrett v Lidl Ltd [2010] All ER D 07 (Feb) EATLeeds Teaching Hospital NHS Trust v Foster UKEAT/0552/10Wolfe v North Middlesex University Hospital NHS Trust [2015] ICR 960Graham v Secretary of State for Work and Pensions (JobCentre Plus) [2012] EWCA Civ 903DB Schenker Rail (UK) Ltd v Doolan [2010]Spencer v Paragon Wallpapers Ltd [1976] IRLR 373Merseyside and North Wales Electricity Board v Taylor [1975] IRLR 60Garricks (Caterers) Ltd v Nolan [1980] IRLR 259Chief Constable of Gwent Police v Parsons and Roberts UKEAT/0143/18Hensman v Ministry of Defence EAT [2014] EqLR 670City of York Council v Grosset [2018] EWCA Civ 1105

Statutes

s.21 Equality Act 2010s.123 Equality Act 2010s.15 Equality Act 2010s.20 Equality Act 2010

Case details

Case number
2219585/2024
Decision date
22 September 2025
Hearing type
full merits
Hearing days
5
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
barrister

Employment details

Role
Security Officer
Service
18 years

Claimant representation

Represented
Yes
Rep type
lay rep