Cases1303401/2023

Claimant v Solihull Community Housing Limited

11 June 2025Before Employment Judge C TaylorMidlands Westin person

Outcome

Claimant fails

Individual claims

Failure to Make Reasonable Adjustments(disability)failed

The tribunal found that the PCP (requiring applicants to evidence in writing that they met essential criteria) did not put the claimant at a substantial disadvantage compared to non-disabled persons. The claimant's own evidence stated he had excellent written communication skills, and his witness statements and other litigation documents demonstrated clear and articulate written communication. The medical evidence did not support substantial disadvantage in written communication, with the 1997 report only noting style issues not content. The tribunal distinguished this case from GLS v Brookes where social imagination was required for hypothetical scenarios, finding that recalling examples from one's own life did not require social imagination and there was no medical evidence the claimant had memory recall difficulties.

Facts

The claimant, who has autism and dyslexia, applied for a part-time Accounts Manager role. He submitted a late application and requested as a reasonable adjustment that the respondent contact him to clarify anything missing before making a decision not to interview him. The respondent did not do so, believing it would disadvantage other candidates. The claimant scored 7-8 out of 15 on the essential criteria and was not shortlisted for interview (the threshold was 10/15). He brought a claim for failure to make reasonable adjustments, arguing that requiring him to evidence skills in writing placed him at a substantial disadvantage due to his disabilities.

Decision

The tribunal dismissed the claim. They found that the PCP did not place the claimant at a substantial disadvantage. The medical evidence did not support that he had difficulties with written communication content (only style issues in a 1997 report). The claimant stated he had excellent written communication skills on his application form and his witness statements and litigation documents demonstrated clear written communication. The tribunal distinguished cases requiring social imagination for hypothetical scenarios, finding that recalling real-life examples did not require this and there was no medical evidence the claimant had memory recall difficulties.

Practical note

In reasonable adjustment claims relating to job applications, tribunals will scrutinise whether medical and objective evidence supports the alleged substantial disadvantage, and may give weight to the claimant's own statements about their abilities and their demonstrated performance in other written tasks.

Legal authorities cited

Secretary of State for Work & Pensions (Job Centre Plus) v Higgins [2014] ICRGovernment Legal Service v Brookes UKEAT/0302/16Paulley v FirstGroup plc [2014] EWCA Civ 1573Bethnal Green & Shoreditch Educational Trust v Dippenaar UKEAT/0064/17Project Management Institute v Latif [2007] IRLR 579Smooth v Churchills Stairlifts plc [2006] ICR 524Newcastle upon Tyne Hospitals NHS Trust v Bagley UKEAT/0417/11Sheikholeslami v University of Edinburgh UKEAT/0014/17

Statutes

Equality Act 2010 s.39Equality Act 2010 s.21Equality Act 2010 s.20

Case details

Case number
1303401/2023
Decision date
11 June 2025
Hearing type
full merits
Hearing days
6
Classification
contested

Respondent

Sector
public sector
Represented
Yes
Rep type
barrister

Employment details

Role
Applicant for part-time Accounts Manager role (not hired)

Claimant representation

Represented
No