Cases8000543/2025

Claimant v Group Employment Services Limited

14 July 2025Before Employment Judge J McCluskeyScotlandremote video

Outcome

Other

Individual claims

Indirect Discrimination(religion)not determined

This preliminary hearing determined that the tribunal has jurisdiction to hear the claim. The tribunal extended the time limit on just and equitable grounds, finding that the claimant had delayed due to fear of losing his job and supporting his family, and acted promptly once a subsequent discriminatory act occurred. The claim will proceed to a full merits hearing.

Direct Discrimination(religion)not determined

This claim concerning non-payment of bonus in December 2024 was the subject of a strike-out application by the respondent. The tribunal refused the strike-out application and refused the alternative deposit order application, finding there was a core of disputed facts (including whether others with similar training issues received bonuses, and whether a previous comment about wearing a turban was made) and the claim could not be said to have no or little reasonable prospect of success. The claim will proceed to a full merits hearing.

Facts

The claimant, a Sikh security worker employed by the respondent at BP premises in Peterhead since April 2023, alleged his manager told him in a phone call (around May 2024) that he could not wear a turban on-site. He did not complain at the time, fearing dismissal as he has a family to support. In December 2024, he was the only member of his six-person team not to receive a bonus. He then raised a grievance about both matters, which was not upheld. He brought tribunal claims alleging indirect and direct religion discrimination.

Decision

This was a preliminary hearing on jurisdiction and strike-out applications. The tribunal extended time on just and equitable grounds for the indirect discrimination claim (207 days late), accepting the claimant's fear of job loss as explanation for delay. The tribunal refused the respondent's applications to strike out or impose a deposit order on the direct discrimination claim about the bonus, finding there were disputed facts about training completion, bonus criteria application, and the alleged comment about wearing a turban. Both claims will proceed to a full merits hearing.

Practical note

Tribunals will be cautious about striking out discrimination claims where there are disputed facts, particularly regarding the mental processes and motivations of alleged discriminators, even where the respondent points to documentary evidence; fear of job loss can justify extending time limits on just and equitable grounds where a claimant acts promptly after a subsequent discriminatory act.

Legal authorities cited

Sharma v New College Nottingham EAT 0287/11Robertson v Bexley Community Centre [2003] IRLR 434British Coal Corporation v Keeble IRLR 336London Borough of Southwark v Afolabi [2003] IRLR 220Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] EWCA Civ 640Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Xie v E'Quipe Japan Limited [2024] EAT 176Anyanwu v South Bank Student Union [2001] ICR 391Mechkarov v Citibank NA [2016] ICRCox v Adecco Group UK & Ireland [2021] ICR 1307Ezsias v North Glamorgan NHS Trust [2007] EWCA Civ 330Zeb v Xerox (UK) Ltd UKEAT/0091/15/DMRomanowska v Aspirations Care Ltd UKEAT/0015/14/SMSpaceman v ISS Mediclean Ltd [2019] ICR 687

Statutes

Equality Act 2010 s.123

Case details

Case number
8000543/2025
Decision date
14 July 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
professional services
Represented
Yes
Rep type
lay rep

Employment details

Role
security role
Service
2 years

Claimant representation

Represented
No