Cases2409028/2023

Claimant v WCF Limited

31 July 2025Before Employment Judge R LloydManchesterremote video

Outcome

Other

Individual claims

Direct Discrimination(disability)not determined

This was a preliminary hearing to determine a strike-out and deposit order application only. The tribunal refused to strike out the disability discrimination claim (based on associative discrimination relating to the claimant's wife's terminal cancer) finding there were clear disputes of fact on key issues not capable of determination without hearing evidence. The merits will be determined at a full hearing.

Unfair Dismissalnot determined

This claim was mentioned as part of the overall case but was not the subject of this preliminary hearing. It will be determined at the full merits hearing.

Breach of Contractnot determined

Notice pay claim mentioned but not determined at this preliminary hearing. It will be determined at the full merits hearing.

Facts

In January 2023 the claimant learned his wife had terminal brain cancer. Shortly after, the respondent put him on a performance improvement plan (related to earlier failure to tax company vehicles in October 2022), removed his email access, and allegedly excluded him from communications. He claims this treatment amounted to associative disability discrimination. The respondent argued the performance issues predated knowledge of his wife's illness and were genuine concerns.

Decision

The tribunal refused the respondent's application to strike out the disability discrimination claim and refused to make a deposit order. There were clear factual disputes on key issues that could not be determined without hearing evidence at a full merits hearing. The tribunal could not conclude the claim had no reasonable prospect or little reasonable prospect of success.

Practical note

Associative disability discrimination claims involving factual disputes about timing and motivation cannot be struck out at a preliminary stage, even where the respondent presents an alternative explanation for the treatment.

Legal authorities cited

Abertawe Bro Morgannwg University Health Board v Ferguson [2013] ICR 1108Hemdan v Ishmail [2017] IRLR 228Cox v Adecco [2021] ICR 1307HM Prison Service v Dolby [2003] IRLR 694Hassan v Tesco Stores Ltd UKEAT/0098/16Mbuisa v Cygnet Healthcare Ltd EAT 0119/18North Glamorgan NHS Trust v Ezsias [2007] IRLR 603

Statutes

Employment Tribunals Rules Rule 39Employment Tribunals Rules Rule 37Equality Act 2010 s.13

Case details

Case number
2409028/2023
Decision date
31 July 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
barrister