Cases3311188/2023

Claimant v Oxford University Hospitals NHS Foundation Trust

30 June 2025Before Employment Judge BoyesBury St Edmundsremote video

Outcome

Partly successful

Individual claims

Constructive Dismissalnot determined

This claim was not determined at the preliminary hearing. The tribunal found it had jurisdiction to hear it (not premature) and it will proceed to a full merits hearing.

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. Although he had depression causing substantial adverse effects on day-to-day activities, the impairment had not lasted 12 months and the evidence was insufficient to show it was likely to last 12 months from the date of the alleged discriminatory acts.

Direct Discrimination(sex)withdrawn

The claimant accepted in oral evidence that he ticked the 'sex discrimination' box in error and did not provide any further details. This claim was effectively abandoned.

Victimisationnot determined

This claim was not determined at the preliminary hearing and will proceed to a full merits hearing.

Othernot determined

Claim for less favourable treatment as a fixed-term employee was not determined at the preliminary hearing and will proceed to a full merits hearing.

Breach of Contractstruck out

The tribunal found it had no jurisdiction to hear this claim because it was presented prematurely. The claim was lodged on 26 September 2023 before the effective date of termination on 26 November 2023. Under Capek v Lincolnshire County Council, breach of contract claims cannot be brought before the contract terminates.

Facts

The claimant worked for the NHS Trust on a series of fixed-term contracts from 2018. From December 2020 he received an uplift from Band 5 to Band 6 to cover additional duties. In February 2023 he was told the uplift would end and he would revert to Band 5 from April 2023. He raised a grievance and went off sick with depression from March 2023. He resigned in September 2023 with effect from November 2023 while still off sick and brought claims including constructive dismissal, disability discrimination, and breach of contract.

Decision

The tribunal found it had jurisdiction to hear the unfair dismissal claim (not premature) but no jurisdiction over the breach of contract claim (presented before termination). The tribunal found the claimant was not disabled under the Equality Act 2010 because although he had depression causing substantial adverse effects, the evidence was insufficient to show it was likely to last 12 months from the date of the alleged discriminatory acts.

Practical note

Even where depression causes substantial adverse effects on day-to-day activities and is medically diagnosed, a claimant must provide sufficient evidence (often expert medical evidence) that the condition is likely to last 12 months from the date of the alleged discrimination, particularly where the condition appears linked to resolving workplace issues.

Legal authorities cited

Goodwin v Patent Office [1999] ICR 302Sullivan v Bury Street Capital Limited [2021] EWCA Civ 1694J v DLA Piper UK LLP 2010 ICR 1052Herry v Dudley Metropolitan Council 2017 ICR 610Igweike v TSB Bank plc 2020 IRLR 267Saad v University Hospital Southampton NHS Trust EAT 0184/14Capek v Lincolnshire County Council 2000 ICR 878Compass Group UK & Ireland Ltd v Morgan [2016] IRLR 924McDougall v Richmond Adult Community College 2008 ICR 431Boyle v SCA Packaging Ltd 2009 ICR 1056

Statutes

Equality Act 2010 Schedule 1 para 2Employment Tribunals Extension of Jurisdiction (England and Wales) Order 1994 Article 7ERA 1996 s.111(3)Equality Act 2010 s.6

Case details

Case number
3311188/2023
Decision date
30 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
healthcare
Represented
Yes
Rep type
barrister

Employment details

Role
Band 5 Senior Clinical Data Coordinator / Band 6 Clinical Data Manager
Service
5 years

Claimant representation

Represented
No