Cases6001450/2024

Claimant v Santander UK PLC

4 September 2025Before Employment Judge JM WadeLeedsin person

Outcome

Partly successful

Individual claims

Failure to Make Reasonable Adjustments(disability)partly succeeded

Seven reasonable adjustment claims from November 2023 to September 2024 were accepted as in time and permitted to proceed. Three historic reasonable adjustment claims from 2017-2021 were struck out for being out of time, with no reasonable prospect of a Tribunal granting a just and equitable extension given the gap of over two years to in-time allegations, the claimant's union membership from 2018, and the balance of prejudice favouring the respondent.

Whistleblowingpartly succeeded

Sixteen in-time whistleblowing detriment allegations from November 2023 to September 2024 were permitted to proceed. Eight historic whistleblowing allegations from 2016-2021 (allegations 11-18) were struck out as there was no reasonable prospect of establishing a series extending to 2023-2024 given the two-year gap, different perpetrators, and no reasonable prospect that it was not reasonably practicable to present the claims earlier.

Victimisationpartly succeeded

In-time victimisation allegations were permitted to proceed. Historic victimisation allegations (11-18) from 2016-2021 were struck out with no reasonable prospect of establishing conduct extending over a period due to the two-year gap and different alleged perpetrators, and no reasonable prospect of a just and equitable extension given the forensic prejudice (witnesses challenged on events 8-10 years prior), claimant's knowledge of Tribunals from 2023 via husband's case, and that fear was overcome to present internal grievance in 2022.

Direct Discrimination(race)struck out

Race discrimination allegations (35-41) from 2010-2021 were struck out as there was no reasonable prospect of a Tribunal granting a just and equitable extension given the stale nature of allegations (10+ years old by hearing), forensic prejudice to respondent, claimant's knowledge of rights, and that these historic wrongs were addressed via internal grievance supported by union.

Direct Discrimination(religion)partly succeeded

One in-time indirect discrimination claim on grounds of religion from June 2024 was accepted as in time and permitted to proceed. Historic religion-based harassment allegations were struck out on time limit grounds as part of allegations 35-41.

Direct Discrimination(sex)struck out

Sexual harassment allegations from 2014-2021 (part of allegations 35-41 and allegation 25 regarding sexual harassment by Mr Beckram in January 2021) were struck out with no reasonable prospect of just and equitable extension given the delay, forensic prejudice, and claimant's opportunity to bring claims earlier.

Harassment(pregnancy)struck out

Allegation 41, a harassment claim on grounds of pregnancy from 2013, was struck out both on time limit grounds and because harassment on grounds of pregnancy and maternity is not a protected characteristic under Section 26 of the Equality Act 2010.

Facts

The claimant worked for Santander from 2007 and was on continuous sick leave from August 2021, eventually dismissed in January 2025. She brought extensive claims alleging discrimination, harassment, victimisation and whistleblowing detriments primarily by her manager's manager Mr Driver, spanning 2010-2024. The claims included historic allegations from 2010-2021 and in-time allegations from November 2023-September 2024 concerning grievance handling and absence management. The claimant had been unwell on multiple occasions since 2016 with anxiety/depression, had two periods of maternity leave, joined a union in 2018, and presented an internal grievance in January 2022.

Decision

The Tribunal struck out all historic allegations from 2010-2021 (allegations 11-18, 26-28, and 35-41) on time limit grounds. There was no reasonable prospect of establishing conduct extending over a period due to the two-year gap to in-time allegations and different perpetrators, nor of obtaining a just and equitable extension given the forensic prejudice, the claimant's knowledge of rights (especially from her husband's 2023 Tribunal case), her union membership from 2018, and the internal grievance process. The in-time claims from November 2023 onwards (reasonable adjustments, victimisation, whistleblowing and indirect discrimination) were permitted to proceed to a full merits hearing.

Practical note

Even where a claimant has a disability and young children, Tribunals will not grant just and equitable extensions for claims 3-14 years out of time where the claimant had union membership, knowledge of Tribunals through family litigation, pursued internal grievances, and the respondent would face severe forensic prejudice defending stale allegations.

Legal authorities cited

Robertson v Bexley Community Centre [2003] IRLR 434Commissioner of Police of the Metropolis v Hendricks [2003] ICR CAWorcestershire Health and Care NHS Trust v Allen [2024] EAT 40Mr GS Virdi v Commissioner of Police of the Metropolis [2007] IRLR 24 EATWells Cathedral School Ltd v Souter [2020] EA 000801 JOJKumari v Greater Manchester Mental Health NHS Foundation Trust [2022] EAT 132Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] EWCA Civ 640Afolabi v Southwark LBC [2003] EWCA Civ 15

Statutes

EqA 2010 s.123(3)EqA 2010 s.26Limitation Act 1980 s.33(3)ERA 1996 s.48(3)s.207B ACAS conciliation extensionEqA 2010 s.123(1)

Case details

Case number
6001450/2024
Decision date
4 September 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
financial services
Represented
Yes
Rep type
barrister

Employment details

Service
18 years

Claimant representation

Represented
Yes
Rep type
lay rep