Cases8000201/2025

Claimant v Outcomes First Group Limited

1 August 2025Before Employment Judge J M HendryScotlandremote video

Outcome

Claimant fails

Individual claims

National Minimum Wagestruck out

Struck out as out of time. Last payment due 30 November 2023. Time limit expired 29 February 2024. Claim presented 24 January 2025, 10 months 27 days late. Claimant failed to show it was not reasonably practicable to bring claim on time.

Holiday Paystruck out

Struck out as out of time under Working Time Regulations. Claimant went off sick 13 November 2023 and made no holiday requests thereafter. Any pre-sickness claims time-barred under reg.30. Time limit expired 12 February 2024, claim presented 11 months 13 days late.

Whistleblowingstruck out

Struck out as out of time and no reasonably practicable extension. Alleged detriments occurred while claimant was at work, ending November 2023. Disclosures insufficiently specific to amount to protected disclosures under s.41A ERA 1996. Claimant failed to demonstrate it was not reasonably practicable to bring claim on time.

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

Struck out as out of time with no just and equitable extension. Any discrimination predated sickness absence in November 2023. Tribunal found claims vague and lacking merit. Claimant contacted ACAS mid-2023 but did not pursue claims. Tribunal unconvinced she could not have raised proceedings earlier despite health difficulties.

Harassment(disability)struck out

Struck out as out of time with no just and equitable extension. Any harassment occurred before sickness absence November 2023. Claimant failed to show harassment was related to disability; tribunal found respondent had reason for disciplinary action unrelated to disability. Claims lacked sufficient particularity.

Otherwithdrawn

Claim under Part Time Workers (Prevention of Less Favourable Treatment) Regulations 2000 was withdrawn by the claimant and therefore dismissed.

Equal Pay(sex)not determined

Equal pay (like work) claim was not subject to strike out or time bar and remains to be determined. This claim was not addressed at this preliminary hearing.

Unlawful Deduction from Wagesstruck out

Struck out as out of time. Sick pay entitlement expired 10 July 2024. Time limit expired 9 October 2024. Claim presented 24 January 2025, 3 months 16 days late. Claimant failed to show it was not reasonably practicable to bring claim on time.

Facts

Claimant was a Care Support Worker at respondent's residential schools for autistic children. She went on long-term sick leave on 13 November 2023 following workplace injury and stress arising from disciplinary proceedings, difficulties with an aggressive pupil and parent, and alleged pay issues relating to annualised hours and introduction of a four-day working week. She contacted ACAS mid-2023 for advice but did not apply for early conciliation until 11 November 2024, presenting her claim on 24 January 2025. Claims included minimum wage, holiday pay, whistleblowing detriment, disability discrimination and harassment.

Decision

Tribunal struck out all claims except equal pay on grounds of time bar. Claims for minimum wage, holiday pay and whistleblowing detriment were 3-11 months out of time and claimant failed to show it was not reasonably practicable to bring them on time. Disability discrimination and harassment claims were also out of time and tribunal refused just and equitable extension, finding claims vague and lacking in merit. Tribunal found claimant had good and bad days and could have pursued claims earlier, especially as she had contacted ACAS mid-2023.

Practical note

Even where a claimant faces genuine health difficulties, the tribunal will not extend time if they had capacity to bring claims earlier (evidenced by seeking ACAS advice), the claims lack merit and particularity, and significant delay is unexplained.

Legal authorities cited

Robertson v Bexley Community Centre [2003] IRLR 434Abertawe Bro Morgannwg University Local Health v Morgan [2018] EWCA CIV 640Pathan v London South Islamic Centre EAT 0312/13Kumari v Greater Manchester Mental Health NHS Foundation Trust (2022 EAT 123)Blockbuster Entertainment v James [2006] EWCA Civ 684

Statutes

Employment Rights Act 1996 s.23(2)Equality Act 2010 s.123Equality Act 2010 s.13(1)Employment Rights Act 1996 s.41AWorking Time Regulations reg.13AWorking Time Regulations reg.13Working Time Regulations reg.30(1)(a)(i)Health & Safety at Work Act 1974Public Interest Disclosure Act 1998Management of Health and Safety Regulations 1999

Case details

Case number
8000201/2025
Decision date
1 August 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
education
Represented
Yes
Rep type
barrister

Employment details

Role
Care Support Worker

Claimant representation

Represented
No