Cases8000076/2025

Claimant v NHS24

23 July 2025Before Employment Judge B CampbellScotlandremote video

Outcome

Claimant fails

Individual claims

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

Tribunal found claim was out of time and it was not just and equitable to extend time. Claimant had consciously chosen not to pursue the matter when capable of doing so in December 2023 and again in summer 2024. She only sought advice in December 2024, almost a year late.

Indirect Discrimination(disability)struck out

Struck out as out of time for same reasons as discrimination arising from disability claim. Claimant was medically capable of pursuing claim in December 2023 and by July/August 2024 but chose not to.

Failure to Make Reasonable Adjustments(disability)struck out

Struck out as out of time. Tribunal held it was not just and equitable to extend time given claimant had consciously decided not to explore legal options in December 2023 out of concern it would damage future NHS employment prospects, and could have revisited this in summer 2024 but did not.

Facts

Claimant applied for role with NHS24 in April 2023 and received conditional offer in May 2023. After period exploring adjustments for her disabilities with Occupational Health, the offer was withdrawn on 18 December 2023, allegedly because specialist software was incompatible and adjustable desk could not be obtained. Claimant commenced ACAS Early Conciliation on 12 December 2024 and filed claim on 10 January 2025, almost a year out of time. She cited illness including Covid-19 in early 2024 and mental health decline from January to October 2024, and lack of knowledge that job applicants could bring discrimination claims.

Decision

Tribunal dismissed claim as out of time, finding it not just and equitable to extend. Key factors were that claimant consciously chose not to pursue claim in December 2023 out of concern for future NHS job prospects despite being capable of doing so, and could have revisited the matter by summer 2024 when her mental health improved but did not. Tribunal held she should have known or taken reasonable steps to discover her legal rights.

Practical note

A claimant's conscious decision not to pursue legal advice or a claim for strategic employment reasons, followed by significant delay, will generally not support a just and equitable extension of time even where the claim appears to have merit and the claimant later experiences health difficulties.

Legal authorities cited

Keeble v British Coal Corporation [1997] IRLR 336DPP v Marshall [1998] IRLR 494Kumari v Greater Manchester Mental Health NHS Foundation Trust [2022] EAT 132Perth & Kinross Council v Townsley UKEATS/0010/10/BMensah v Royal College of Midwives EAT/124/94

Statutes

Equality Act 2010 s.20Equality Act 2010 s.123(1)(b)Equality Act 2010 s.21Equality Act 2010 s.6Equality Act 2010 s.15Equality Act 2010 s.19

Case details

Case number
8000076/2025
Decision date
23 July 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Name
NHS24
Sector
healthcare
Represented
Yes
Rep type
solicitor

Employment details

Role
Psychological Wellbeing Officer

Claimant representation

Represented
Yes
Rep type
solicitor