Cases2307676/2023

Claimant v HCA International Limited

14 August 2025Before Employment Judge Mr J S BurnsLondon Southremote video

Outcome

Claimant fails

Individual claims

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

Claims pre-dating 11/10/2023 in the second claim were struck out as vexatious and an abuse of process because the claimant brought a second claim raising matters that could and should have been included in the first claim by amendment, causing duplication and inconsistency.

Direct Discrimination(race)struck out

Claims pre-dating 11/10/2023 in the second claim were struck out as vexatious and an abuse of process because the claimant brought a second claim raising matters that could and should have been included in the first claim by amendment, causing duplication and inconsistency.

Unfair Dismissalstruck out

Claims pre-dating 11/10/2023 in the second claim were struck out as vexatious and an abuse of process because the claimant brought a second claim raising matters that could and should have been included in the first claim by amendment, causing duplication and inconsistency.

Whistleblowingstruck out

Claims pre-dating 11/10/2023 in the second claim were struck out as vexatious and an abuse of process because the claimant brought a second claim raising matters that could and should have been included in the first claim by amendment, causing duplication and inconsistency. Tribunal noted no comprehensible cause of action was pleaded.

Victimisationpartly succeeded

Victimisation claims relating to post-1/4/2023 detriment were permitted to proceed, and the claimant may rely on claimed protected acts prior to 1/4/2023 in support of those claims, as there was no good reason to preclude the tribunal from considering those earlier protected acts.

Facts

The claimant brought two separate tribunal claims against HCA International Limited. The first claim (December 2023) covered disability discrimination from 1 April to 11 October 2023, expressly excluding earlier matters as background only. The second claim (February 2024) added race discrimination, unfair dismissal, and whistleblowing claims, and included inconsistent and expanded allegations covering both before and after 11 October 2023, overlapping substantially with the first claim but with material differences and new averments. The claimant is a litigant in person with mental health issues, assisted by a Spanish/English interpreter.

Decision

The tribunal struck out as vexatious and an abuse of process any claims and allegations in the second claim that pre-dated 11 October 2025 [sic - should be 2023]. The tribunal found the claimant had deliberately chosen to exclude pre-April 2023 matters from the first claim, then changed his mind without applying to amend. By bringing a second claim with overlapping but inconsistent allegations, he wasted tribunal resources and subjected the respondents to disproportionate inconvenience. An exception was made for claimed protected acts prior to 1 April 2023 relied upon for post-1 April 2023 victimisation claims.

Practical note

Bringing a second claim that duplicates or inconsistently re-pleads matters that could and should have been raised in a first claim by amendment will likely be struck out as an abuse of process, following the principles in Henderson v Henderson and Szucs v Greensquareaccord.

Legal authorities cited

Scott v Russell 2013 EWCA Civ 1432Attorney General v Barker 2000 1 FLR 759Henderson v Henderson 1843 3 Hare 100Talbot v Berkshire CC [1993] 4 All ER 9Manson v Vooght [1999] BPIR 376Franked Income Investment Group Litigation v Revenue and Customs Commissioners [2020] UKSC 47Foster v Bon Groundwork 2012 EWCA Civ 252Sheriff v Klyne Tugs (Lowestoft) Ltd 1999 IRLR 481Thomas v Devon County Council UKEAT/0513/07London Borough of Haringey v O'Brien UKEAT/0004/16Szucs v Greensquareaccord Ltd EA-2023-000770-RN

Case details

Case number
2307676/2023
Decision date
14 August 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No