Cases8000577/2025

Claimant v Sky Subscriber Services Limited

30 June 2025Before Employment Judge A KempScotlandremote video

Outcome

Partly successful

Individual claims

Unfair Dismissalstruck out

The tribunal found the claimant did not discharge the burden of proof that it was not reasonably practicable to present the claim on time. Despite mental health impacts and a medical condition, the claimant was looking for work, caring for her son, and engaged with ACAS, indicating cognitive ability to research time limits online. No substantial impediment to timely filing was established.

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

The tribunal extended jurisdiction under section 123 of the Equality Act 2010 on a just and equitable basis. The nine-day delay was short, the claimant had reasonable explanations (medical condition, planned operation, mental health impact), no forensic prejudice to respondent, and the claimant is unrepresented. Case to proceed to full merits hearing.

Failure to Make Reasonable Adjustments(disability)not determined

The tribunal extended jurisdiction under section 123 of the Equality Act 2010 on a just and equitable basis. The nine-day delay was short, the claimant had reasonable explanations (medical condition, planned operation, mental health impact), no forensic prejudice to respondent, and the claimant is unrepresented. Case to proceed to full merits hearing.

Facts

The claimant was employed as a Site Co-ordinator for over 11 years and was dismissed by redundancy on 26 September 2024. She suffers from Charcot-Marie-Tooth disease causing chronic pain and takes strong medication including Pregabalin. She commenced ACAS early conciliation timeously on 12 December 2024, with certificate issued 23 January 2025, but did not file her claim until 4 March 2025, nine days outside the one-month deadline. She is a single mother caring for a seven-year-old child and had a foot operation planned (which was cancelled twice before taking place in April 2025).

Decision

The tribunal dismissed the unfair dismissal claim as the claimant failed to establish it was not reasonably practicable to file in time, given she was looking for work, caring for her child, and engaged with ACAS, all indicating cognitive ability to research time limits. However, the tribunal extended time for the disability discrimination claims under the just and equitable test, finding the nine-day delay short, the claimant's medical and personal circumstances a reasonable explanation, no forensic prejudice to the respondent, and the claimant unrepresented.

Practical note

The 'reasonably practicable' test for unfair dismissal time limits is significantly stricter than the 'just and equitable' test for discrimination claims; a claimant's ability to perform other cognitively demanding tasks during the limitation period may undermine an argument that ignorance of time limits was reasonable.

Legal authorities cited

Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Porter v Bandridge Ltd [1978] IRLR 271Palmer v Southend on Sea Borough Council [1984] IRLR 119Marks and Spencer plc v Williams-Ryan [2005] IRLR 562Robertson v Bexley Community Centre [2003] IRLR 434Abertawe Bro Morgannwg University LHB v Morgan [2018] ICR 1194Malcolm v Dundee City Council 2012 SLT 457

Statutes

ERA 1996 s.94EqA 2010 s.15EqA 2010 s.20/21ERA 1996 s.111EqA 2010 s.123

Case details

Case number
8000577/2025
Decision date
30 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
telecoms
Represented
Yes
Rep type
lay rep

Employment details

Role
Site Co-ordinator
Service
11 years

Claimant representation

Represented
No