Cases2208546/2023

Claimant v City of Westminster

6 June 2025Before Employment Judge T.R. SmithLondon Centralremote video

Outcome

Partly successful£5,000

Individual claims

Harassment(disability)succeeded

The claimant was not shortlisted for a Public Health role on 24 February 2023, where the shortlisting used factors not listed in the advertisement or job description. The tribunal found this created a humiliating environment in the highly fact-specific circumstances of the case (involving a context of unsuccessful job applications), although it was unintentional. This amounted to harassment related to disability.

Direct Discrimination(disability)failed

The tribunal did not uphold the claimant's claims of direct disability discrimination across the various allegations considered at the liability hearing.

Discrimination Arising from Disability (s.15)(disability)failed

The tribunal did not uphold the claimant's claims of unfavourable treatment because of something arising in consequence of disability.

Failure to Make Reasonable Adjustments(disability)failed

The tribunal did not uphold the claimant's claims that the respondent failed to make reasonable adjustments for her disability.

Facts

The claimant, who has disabilities including ADHD and autism, applied for a Public Health role with Westminster City Council. On 24 February 2023, she was not shortlisted for the role because the shortlisting used criteria not listed in the job advertisement or description, raising concerns about fairness. The respondent investigated her complaint, found indirect discrimination, and took steps to prevent repetition. The claimant had experienced declining mental health during maternity leave and found many aspects of her employment upsetting, though most did not amount to discrimination.

Decision

The tribunal upheld one claim of harassment related to disability concerning the February 2023 job application. The tribunal awarded £5,000 for injury to feelings in the lower Vento band, finding this was a single isolated event causing some but not very serious distress. No award was made for psychiatric injury or financial loss. The claimant's other claims for direct discrimination, discrimination arising from disability, failure to make reasonable adjustments, and other harassment allegations failed.

Practical note

Even where a claimant experiences significant general upset at work and has pre-existing mental health conditions, tribunals will carefully apportion injury to feelings only to the specific discriminatory acts proven, applying divisibility principles where there is a rational basis to separate the effects of lawful and unlawful conduct.

Award breakdown

Injury to feelings£5,000

Vento band: lower

Legal authorities cited

Armitage, Marsden and HM Prison Service v Johnson [1997] IRLR 162Vento v Chief Constable of West Yorkshire Police [2003] ICR 318Chagger v Abbey National Plc [2010] ICR 397Sienkiewicz v Grief (UK) Ltd [2011] 2 AC 229Rahman v Arearose Limited [2001] QB 351BAE Systems (Operations) Ltd v Konczak [2017] EWCA Civ 1188Olayemi v Athena Medical Centre & anor UKEAT/0140/15Hatton v Sutherland and others [2002] ICR 613 CASharma v University of Portsmouth [2025] EAT 19Ministry of Defence v Cannock

Statutes

Employment Tribunals (Interest on Awards in Discrimination Cases) Regulations 1996

Case details

Case number
2208546/2023
Decision date
6 June 2025
Hearing type
remedy
Hearing days
1
Classification
contested

Respondent

Sector
local government
Represented
Yes
Rep type
barrister

Claimant representation

Represented
No