Cases2402344/2020

Claimant v AO World plc

30 May 2025Before Employment Judge Phil AllenManchesterremote video

Outcome

Claimant fails

Individual claims

Harassment(disability)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Harassment(sex)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Direct Discrimination(disability)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Direct Discrimination(sex)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Discrimination Arising from Disability (s.15)(disability)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Failure to Make Reasonable Adjustments(disability)struck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Unfair Dismissalstruck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Unlawful Deduction from Wagesstruck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Holiday Paystruck out

Claimant's claims were struck out for non-compliance with an unless order made by Employment Judge Leach on 11 July 2024. The claimant failed to provide the required medical evidence and records by the deadline of 6 September 2024. Relief from sanctions was refused.

Facts

Ms Patel worked as a Project Consultant for AO World plc from September 2019 until March 2022, having been absent from work from November 2019 after not completing probation. She brought two claims in 2021 and 2022, alleging discrimination on grounds of disability and sex, harassment, unfair dismissal, and wage-related claims. After repeatedly failing to comply with tribunal orders, her claims were struck out for non-compliance with an unless order requiring medical evidence by 6 September 2024. She applied for relief from sanctions.

Decision

The tribunal refused relief from sanctions. Although the claimant's failure to comply was not deliberate and was health-related, the tribunal considered the extensive procedural history involving multiple postponements, all health-related, the significant prejudice to the respondent and other tribunal users, and GP advice indicating the claimant would need a further six-month stay. The interests of justice, considering the overriding objective, favoured refusing relief despite prejudice to the claimant.

Practical note

Even where non-compliance with an unless order is health-related and non-deliberate, relief from sanctions may be refused where there is a lengthy history of postponements, ongoing unfitness, significant prejudice to the respondent and tribunal system, and no realistic prospect of an imminent final hearing.

Legal authorities cited

Minnoch v Interserve FM Ltd 2023 ICR 861Neary v St Albans School for Girls Governors 2010 IRLR 124Thind v Salvesen Logistics Ltd EAT 0487/09

Statutes

Employment Tribunal Rules of Procedure rule 39(2)Equality Act 2010 s.20Employment Tribunal Rules of Procedure rule 32

Case details

Case number
2402344/2020
Decision date
30 May 2025
Hearing type
reconsideration
Hearing days
1
Classification
procedural

Respondent

Sector
retail
Represented
Yes
Rep type
barrister

Employment details

Role
Project Consultant
Service
3 years

Claimant representation

Represented
No