Cases6002342/2025

Claimant v Sainsbury's Supermarkets Ltd

31 July 2025Before Employment Judge Mr J S BurnsLondon Centralremote video

Outcome

Claimant fails

Individual claims

Unfair Dismissalstruck out

Struck out as outside tribunal jurisdiction. Claim presented nearly two months late. Tribunal found it was not reasonably practicable to present claim within three months and was not presented within reasonable time thereafter. Claimant was aware of time limits, took advice from CAB, but failed to comply.

Direct Discrimination(race)struck out

Struck out as outside tribunal jurisdiction. Claims related to matters from late 2021 onwards were at least 14 months out of time. Tribunal held it was not just and equitable to extend time given the length of delay, lack of good reason, and prejudice to respondent in investigating stale claims where evidence would be affected.

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

Struck out as outside tribunal jurisdiction. Tribunal found no medical evidence supporting claimant's assertions of cognitive impairment preventing timely claim. Medical evidence from neurosurgeons showed claimant was well and working. No diagnosis of severe depression/anxiety or PTSD. Not just and equitable to extend time.

Otherstruck out

Unspecified 'other payments' claim struck out as outside tribunal jurisdiction, being presented outside the three month primary limitation period with no good reason for delay and not within reasonable further period.

Facts

Claimant was employed by Sainsbury's from September 2020 until dismissed for ill-health capability on 22 August 2024 (effective date 27 August 2024) after over a year of sick leave following an assault in May 2023. He appealed unsuccessfully and contacted ACAS on 6 December 2024, after the three-month limitation period had expired. He presented his ET1 on 22 January 2025 claiming unfair dismissal, race and disability discrimination relating to matters from late 2021 onwards, and other payments. The claimant attributed the delay to confusion about his dismissal date and claimed mental health issues including PTSD, cognitive impairment, depression and anxiety prevented timely claim submission.

Decision

The tribunal struck out all claims as outside its jurisdiction. The judge found the claimant's evidence about confusion over dismissal date and mental incapacity unconvincing and contradicted by medical evidence showing he was well and functional. The medical evidence did not support claims of cognitive impairment or severe mental illness. The claimant knew the time limits, took advice from CAB, and was able to pursue internal appeals and move house during the relevant period. It was not reasonably practicable to extend time for unfair dismissal, and not just and equitable for discrimination claims given the significant delay and prejudice to the respondent.

Practical note

Claimants asserting mental health as grounds for extending time limits must provide objective medical evidence of incapacity; self-reported symptoms and functional behaviour inconsistent with incapacity will be fatal to such applications.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336Robertson v Bexley Community Centre [2003] IRLR 434Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] IRLR 1050

Statutes

EqA 2010 s.123ERA 1996 s.207BLimitation Act 1980 s.33ERA 1996 s.94ERA 1996 s.111

Case details

Case number
6002342/2025
Decision date
31 July 2025
Hearing type
strike out
Hearing days
1
Classification
procedural

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Service
4 years

Claimant representation

Represented
Yes
Rep type
lay rep