Cases2216708/2024

Claimant v Simmons and Simmons LLP

10 July 2025Before Employment Judge KeoghLondon Central

Outcome

Claimant fails

Individual claims

Direct Discrimination(disability)struck out

The tribunal found that the claimant was not disabled within the meaning of section 6 Equality Act 2010 at the relevant time. The claimant failed to prove that the adverse effects of her impairment were substantial (more than minor or trivial), and even if they were, they had not lasted and were not likely to last 12 months at the relevant time. The claim was therefore struck out.

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

The tribunal found that the claimant was not disabled within the meaning of section 6 Equality Act 2010 at the relevant time. Without establishing disability status, the discrimination arising from disability claim could not proceed. The claim was therefore struck out.

Failure to Make Reasonable Adjustments(disability)struck out

The tribunal found that the claimant was not disabled within the meaning of section 6 Equality Act 2010 at the relevant time. The duty to make reasonable adjustments only arises if the claimant is disabled. As this was not established, the claim was struck out.

Facts

The claimant was employed by a law firm from February to September 2023 on probation. Her probation was twice extended due to performance concerns, and she was ultimately dismissed. She contended she began experiencing fibromyalgia symptoms around April 2023, reporting pain, fatigue, brain fog and headaches to her GP. She believed she was verbally diagnosed with fibromyalgia in August 2023 and was prescribed Amitriptyline. During this period she also suffered multiple family tragedies. She brought claims for disability discrimination but her employment was terminated before she had a formal diagnosis or rheumatology assessment.

Decision

The tribunal struck out all of the claimant's disability discrimination claims, finding she was not disabled within the meaning of the Equality Act 2010 at the relevant time. The tribunal found the claimant had impairments (pain, fatigue, brain fog, headaches) but concluded she had not proven these had a substantial adverse effect on her day-to-day activities, and that even if they did, they were not shown to be long-term (likely to last 12 months) as of September 2023, given symptoms had only been present for around five months and there was no formal diagnosis.

Practical note

A claimant alleging fibromyalgia-based disability must provide credible, detailed evidence of substantial impact on day-to-day activities and likelihood of long-term duration; significantly altering witness statements to address respondent's objections will severely damage credibility and likely lead to claim failure.

Legal authorities cited

Hendricks v Metropolitan Police Commissioner [2003] ICR 530Goodwin v Patent Office [1999] ICR 302Aderemi v London and South Eastern Railway Ltd [2013] ICR 591Ahmed v Metroline Travel Ltd UKEAT/0400/10Royal Borough of Greenwich v Syed UKEAT/0244/14Swift v Chief Constable of Wiltshire Constabulary [2004] ICR 909Nissa v Waverly Education Foundation Limited UKEAT/0135/18/DAMcDougall v Richmond Adult Community College [2008] ICR 431

Statutes

Equality Act 2010 s.6Equality Act 2010 Schedule 1 paragraph 2Equality Act 2010 Schedule 1 paragraph 5Equality Act 2010 s.212

Case details

Case number
2216708/2024
Decision date
10 July 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
legal services
Represented
Yes
Rep type
barrister

Employment details

Service
7 months

Claimant representation

Represented
Yes
Rep type
barrister