Cases8000554/2024

Claimant v South Lanarkshire Council

9 June 2025Before Employment Judge P O'DonnellScotlandin person

Outcome

Partly successful

Individual claims

Constructive Dismissalnot determined

Claim is proceeding to final hearing. This preliminary hearing addressed only jurisdictional and procedural issues, not the merits of the constructive dismissal claim.

Direct Discrimination(age)not determined

Multiple allegations of direct age discrimination are proceeding to final hearing. Tribunal granted amendment to add new allegation relating to failure to give claimant certain work from August 2022 to November 2023. Time bar issues to be determined at final hearing.

Harassment(age)struck out

Claims relating to alleged harassment on 5 February 2015 and 3 April 2019 were struck out as out of time (9 and 5 years late respectively). Tribunal refused to extend time on just and equitable grounds, finding claimant chose not to pursue claims earlier and significant delay would prejudice quality of evidence.

Whistleblowingnot determined

Claim of protected disclosure detriment is proceeding to final hearing. Time bar issues deferred to final hearing to determine whether there was an act continuing over a period.

Facts

The claimant, employed by the respondent council since 2007, brought claims of constructive dismissal, age discrimination, and whistleblowing detriment in April 2024. After extensive case management to clarify the claims, the respondent raised jurisdictional issues regarding a new allegation of direct age discrimination (relating to work allocation from August 2022 to November 2023) and two harassment allegations from February 2015 and April 2019. The claimant explained he had not raised the harassment claims earlier because he considered them 'relatively minor' and wanted to get on with his job.

Decision

The tribunal allowed the claimant's application to amend his claim to add the new direct age discrimination allegation, finding the balance of prejudice favoured the claimant despite the late application. However, it struck out the harassment claims as out of time (9 and 5 years late), refusing to extend time on just and equitable grounds because the claimant had chosen not to pursue them earlier and the significant delay would prejudice the quality of evidence.

Practical note

Tribunals will apply Selkent principles generously to allow amendments adding related allegations even when brought late, but long-delayed harassment claims will be struck out where the claimant made a conscious choice not to pursue them earlier and cannot demonstrate why a time extension would be just and equitable.

Legal authorities cited

Adedeji v University Hospitals Birmingham NHS Foundation Trust [2021] EWCA Civ 23Selkent Bus Co Ltd v Moore [1996] ICR 836Transport and General Workers Union v Safeway Stores Ltd UKEAT/0092/07Galilee v Commissioner of Police of the Metropolis [2018] ICR 634Hendricks v Metropolitan Police Commissioner [2003] ICR 530Douglas v North Lanarkshire Council [2024] EAT 194British Coal Corpn v Keeble [1997] IRLR 336Abertawe Bro Morgannwg University Local Health Board v Morgan [2018] IRLR 1050Robertson v Bexley Community Centre [2003] IRLR 434Pathan v South London Islamic Centre UKEAT/0312/13

Statutes

Employment Rights Act 1996Equality Act 2010 s.123

Case details

Case number
8000554/2024
Decision date
9 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Name
South Lanarkshire Council
Sector
local government
Represented
Yes
Rep type
solicitor

Claimant representation

Represented
No