Cases8000173/2025

Claimant v Red Band Chemical Co. Ltd

10 July 2025Before Employment Judge A KempScotlandhybrid

Outcome

Claimant fails

Individual claims

Constructive Dismissalfailed

Tribunal found no dismissal under s.95(1)(c) ERA 1996. Respondent had addressed relationship issues through mediation, investigations, and regular meetings. Claimant had agreed to reduce hours and then return to former hours, undermining claim. Claimant thanked manager for support. No last straw identified. Even if there was breach, respondent had reasonable and proper cause.

Failure to Make Reasonable Adjustments(disability)failed

Tribunal preferred evidence of managers that prescription 'owings' were placed on counter at waist height each Friday evening as adjustment. Claimant had not complained about this at health review meetings or to managers. Absence of complaint strongly supported respondent's position that adjustment was being made.

Harassment(disability)failed

Tribunal found no conduct was related to claimant's disability. Poor relationships with colleagues pre-dated cancer diagnosis. Social event exclusion, cardboard box incident, holiday refusal, consultation room cleaning request, and HighFive message all unrelated to disability. Some matters handled poorly but not related to protected characteristic. Some claims also out of time.

Facts

Claimant was a pharmacy dispenser who had surgery for cancer in July 2023 and later gynaecological surgery in July 2024. She had poor working relationships with colleague Ms McArthur and manager Mrs Henderson. Issues included exclusion from social event, cardboard box incident, cleaning request after surgery, holiday refusal, and HighFive message thanking staff but excluding claimant. Claimant reduced hours to Saturdays only to avoid working with colleagues, then requested return to 12 hours which was agreed. She resigned on 27 November 2024 citing toxic atmosphere, having secured higher-paid role with Boots.

Decision

Tribunal dismissed all claims. No constructive dismissal found as respondent had addressed relationship issues through mediation, investigations and regular meetings. Reasonable adjustment claim failed as tribunal accepted respondent's evidence that prescriptions were placed at counter height each Friday. Harassment claim failed as no conduct was related to claimant's disability — poor relationships pre-dated diagnosis and matters unrelated to protected characteristic.

Practical note

A difficult working relationship and poor management decisions do not automatically constitute constructive dismissal or disability-related harassment unless causally linked to the protected characteristic and sufficiently serious to breach the implied term of trust and confidence.

Legal authorities cited

Malik v Bank of Credit and Commerce International [1998] AC 20Aberdeen City Council v McNeil [2014] IRLR 113Kaur v Leeds Teaching Hospitals NHS Trust [2018] IRLR 833Omilaju v Waltham Forest LBC [2005] IRLR 35Land Registry v Grant [2011] IRLR 748Tees Esk and Wear Valleys NHS Foundation Trust v Aslam EAT 0039/19Carozzi v University of Hertfordshire [2024] EAT 169Richmond Pharmacology v Dhaliwal [2009] ICR 724Western Excavating v Sharp [1978] ICR 221

Statutes

ERA 1996 s.98EqA 2010 s.20EqA 2010 s.21EqA 2010 s.26EqA 2010 s.39ERA 1996 s.95(1)(c)EqA 2010 s.123EqA 2010 s.136

Case details

Case number
8000173/2025
Decision date
10 July 2025
Hearing type
full merits
Hearing days
4
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
in house

Employment details

Role
Dispenser
Service
5 years

Claimant representation

Represented
No