Cases8001169/2024

Claimant v Lloyds Bank Plc

9 June 2025Before Employment Judge P O'DonnellScotlandon papers

Outcome

Other

Individual claims

Harassment(disability)not determined

This is a preliminary hearing on an amendment application. The claim of harassment related to disability regarding conditional approval of leave request was allowed as a re-labelling of existing facts already pleaded.

Constructive Dismissal(disability)not determined

Tribunal allowed amendment to add constructive dismissal claim (harassment related to disability under s26 EqA) on 29 August 2024, despite being out of time. The matters giving rise to constructive dismissal were already pleaded as discrimination claims. Time bar defence can be raised by respondent at final hearing.

Victimisationnot determined

Tribunal allowed amendment to add victimisation claims under s27 EqA relating to delay in handling grievance and appeal. Respondent did not oppose as claims were in time at date of amendment application.

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

Original claims of disability discrimination under Equality Act 2010 remain to be determined at final hearing. This preliminary hearing dealt only with amendment application.

Facts

The claimant brought claims under the Equality Act 2010 and Employment Rights Act 1996 against her former employer Lloyds Bank. On 16 December 2024, she applied to amend her claim to add harassment allegations regarding leave approval, a constructive dismissal claim based on harassment related to disability (employment ending 29 August 2024), and victimisation claims regarding grievance handling. The respondent opposed only the constructive dismissal element on grounds it was substantially out of time.

Decision

The tribunal allowed all amendments. The constructive dismissal claim was allowed despite being out of time because: the facts were already pleaded in existing discrimination claims; the respondent was already preparing to defend those matters; there was minimal additional prejudice; the claimant would have no remedy for termination if refused; and the respondent could still raise time bar as a defence at the final hearing where evidence could be heard on continuing act and tribunal discretion issues.

Practical note

Tribunals will allow out-of-time amendments to add new claims based on already-pleaded facts where the respondent suffers minimal additional prejudice, particularly when time bar defences can still be argued at the substantive hearing.

Legal authorities cited

Hendricks v Metropolitan Police Commissioner [2003] ICR 530Selkent 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 634Douglas v North Lanarkshire Council [2024] EAT 194

Statutes

Equality Act 2010 s27Equality Act 2010 s26Equality Act 2010 s123(1)(b)Employment Rights Act 1996

Case details

Case number
8001169/2024
Decision date
9 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
financial services
Represented
Yes

Claimant representation

Represented
Yes
Rep type
solicitor