Cases6006601/2024

Claimant v Jaguar Land Rover Limited

2 June 2025Before Employment Judge C KnowlesBirminghamremote video

Outcome

Other

Individual claims

Direct Discrimination(disability)not determined

This was a preliminary hearing on disability status only. The substantive claim of direct disability discrimination under s.13 Equality Act has not yet been determined. The tribunal found the claimant was disabled by reason of chronic pain, PTSD from 6 November 2023, and anxiety/depression from 4 July 2023.

Indirect Discrimination(disability)not determined

This was a preliminary hearing on disability status only. The claim of discrimination arising from disability under s.15 Equality Act has not yet been determined. The tribunal found the claimant met the definition of disability for the relevant period.

Failure to Make Reasonable Adjustments(disability)not determined

This was a preliminary hearing on disability status only. The claim under s.20 and s.21 Equality Act for failure to make reasonable adjustments has not yet been determined. The tribunal found the claimant was disabled during the relevant period.

Harassment(disability)not determined

This was a preliminary hearing on disability status only. The claim of harassment under s.26 Equality Act has not yet been determined. The tribunal found the claimant met the statutory definition of disability.

Whistleblowingnot determined

The claimant brought a complaint of whistleblowing detriment alongside the disability discrimination claims. This preliminary hearing dealt only with disability status. The whistleblowing claim has not yet been determined.

Facts

The claimant, a senior HR professional, suffered catastrophic injuries in a motorbike accident in Spain in November 2022, resulting in chronic pain and multiple fractures. He continued working but from March 2023 developed increasing anxiety and depression, was prescribed propranolol, and his condition deteriorated rapidly from May/July 2023 despite medication. He was signed off work in September 2023 and was diagnosed with PTSD in November 2023. He brought claims for disability discrimination and whistleblowing detriment in July 2024 while still employed.

Decision

The tribunal found the claimant was disabled under the Equality Act by reason of: (1) chronic pain from the accident throughout the relevant period (conceded by respondent); (2) PTSD from 6 November 2023 (conceded); and (3) anxiety and depression from 4 July 2023 to 24 July 2024 (disputed but found by the tribunal). The tribunal also found the cognitive effects of opiate painkillers formed part of the physical impairment rather than a separate disability. This was a preliminary hearing on disability status only; the substantive discrimination and whistleblowing claims remain to be determined.

Practical note

Mental health conditions can meet the definition of disability before formal diagnosis if symptoms have a substantial adverse effect on day-to-day activities and are likely to last 12 months, viewed at the material time without hindsight, and side effects of medication for a physical impairment can form part of that impairment rather than requiring separate analysis.

Legal authorities cited

Aderemi v London and South Eastern Railway Ltd [2013] ICR 591McDougall v Richmond Adult Community College [2008] ICR 431SCA Packaging Ltd v Boyle [2009] ICR 1056Nissa v Waverly Education Foundation Ltd UKEAT/0135/18College of Ripon and York St John v Hobbs [2002] IRLR 185Millar v ICR [2006] IRLR 112Ministry of Defence v Hay [2008] ICR 1247Peart v Dixons Store Group Retail Limited (2004) UKEAT/0630/04Banaszczyk v Booker Ltd [2016] IRLR 273Sussex Partnership NHS Foundation Trust v Norris UK EAT/0031/12Goodwin v Patent Office [1999] ICR 302

Statutes

Equality Act 2010 s.20Equality Act 2010 s.21Equality Act 2010 s.26Equality Act 2010 Sch 1 Part 1 para 2Equality Act 2010 s.212Equality Act 2010 s.6Equality Act 2010 s.13Equality Act 2010 s.15

Case details

Case number
6006601/2024
Decision date
2 June 2025
Hearing type
preliminary
Hearing days
1
Classification
contested

Respondent

Sector
manufacturing
Represented
Yes
Rep type
barrister

Employment details

Role
Head of Human Resources, Overseas

Claimant representation

Represented
Yes
Rep type
barrister