Cases6000054/2024

Claimant v AM Norris Ltd

27 July 2025Before Employment Judge HeapNottinghamin person

Outcome

Partly successful

Individual claims

Unfair Dismissalstruck out

The Claimant lacked the minimum two years qualifying service required under Section 108 Employment Rights Act 1996 to bring an unfair dismissal claim, having only been employed for just shy of seven months. No basis for automatically unfair dismissal was established.

Direct Discrimination(age)not determined

The age discrimination claim continues and was not struck out. Case management orders were made for the claim to proceed to a full merits hearing.

Discrimination Arising from Disability (s.15)(disability)not determined

The disability discrimination claim continues and was not struck out. The tribunal found that, despite delays and non-compliance issues, a fair hearing was still possible and case management orders were made to progress the claim.

Facts

The Claimant, a Polish speaker with health issues and disability, brought claims of unfair dismissal and age and disability discrimination after approximately seven months of employment. The Claimant failed to attend a preliminary hearing in May 2024 due to ill health and initially struggled to comply with Unless Orders requiring medical evidence, though eventually did provide documentation. The Respondent applied to strike out all claims for non-compliance and failure to actively pursue, but the Claimant attended the July 2025 preliminary hearing and resisted the application.

Decision

The tribunal refused the respondent's application to strike out the discrimination claims, finding by the narrowest of margins that a fair hearing was still possible despite significant delays, partly caused by tribunal administrative delays. However, the unfair dismissal claim was struck out as the Claimant lacked the required two years qualifying service under s.108 ERA 1996 and no automatically unfair reason applied. The age and disability discrimination claims continue with case management orders.

Practical note

A claimant with less than two years' service has no standing to bring ordinary unfair dismissal claims, but discrimination claims will be preserved even in the face of significant procedural non-compliance where a fair hearing remains possible and delays are not solely attributable to the claimant.

Legal authorities cited

Riley v Crown Prosecution Service 2013 IRLR 966Anyanwu v South Bank Student Union [2001] ICR 391Peixoto v British Telecommunications plc EAT 0222/07

Statutes

Employment Rights Act 1996 s.108Employment Tribunals (Constitution & Rules of Procedure) Regulations 2024 Rule 38

Case details

Case number
6000054/2024
Decision date
27 July 2025
Hearing type
preliminary
Hearing days
0.5
Classification
contested

Respondent

Sector
other
Represented
Yes
Rep type
solicitor

Employment details

Service
7 months

Claimant representation

Represented
No