Cases3202217/2023

Claimant v London Underground Limited

28 May 2025Before Employment Judge B BeyzadeLondon Eastremote video

Outcome

Partly successful

Individual claims

Unfair Dismissalstruck out

The tribunal struck out the unfair dismissal complaint on the basis that it has no reasonable prospect of success under Rule 38(1)(a) of The Employment Tribunal Procedure Rules 2024.

Breach of Contractstruck out

The tribunal struck out the breach of contract (notice pay) complaint on the basis that it has no reasonable prospect of success under Rule 38(1)(a) of The Employment Tribunal Procedure Rules 2024.

Direct Discrimination(disability)not determined

The tribunal declined to strike out the direct disability discrimination complaint under section 13 of the Equality Act 2010, finding it has sufficient prospect of success to proceed to full hearing.

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

The tribunal declined to strike out the discrimination arising from disability complaint under section 15 of the Equality Act 2010, and it will proceed to full hearing scheduled for July 2025.

Indirect Discrimination(disability)not determined

The tribunal declined to strike out the indirect disability discrimination complaint under section 19 of the Equality Act 2010, and it will proceed to full hearing.

Failure to Make Reasonable Adjustments(disability)not determined

The tribunal declined to strike out the reasonable adjustments complaint under sections 20 and 21 of the Equality Act 2010, finding sufficient merit to proceed to full hearing.

Harassment(disability)not determined

The tribunal declined to strike out the harassment complaint under section 26 of the Equality Act 2010, and it will proceed to full hearing scheduled for July 2025.

Facts

This case involves a claim brought by the personal representatives of Ian McCrow (suggesting he is deceased) against London Underground Limited and three individual respondents. The claim included complaints of unfair dismissal, breach of contract for notice pay, and various disability discrimination claims under the Equality Act 2010. At a preliminary hearing, the respondents applied to strike out certain claims.

Decision

The tribunal struck out the unfair dismissal and breach of contract claims for having no reasonable prospect of success under Rule 38(1)(a). However, all disability discrimination claims (direct discrimination, discrimination arising from disability, indirect discrimination, failure to make reasonable adjustments, and harassment) were allowed to proceed to a full merits hearing scheduled for July 2025.

Practical note

Employment tribunals will strike out claims with no reasonable prospect of success at preliminary hearings, but disability discrimination claims require careful scrutiny and are less likely to be struck out where there is any arguable case to be made.

Legal authorities cited

Statutes

Equality Act 2010 s.13Equality Act 2010 s.15Equality Act 2010 s.19Equality Act 2010 s.20Equality Act 2010 s.21Equality Act 2010 s.26Employment Tribunal Procedure Rules 2024 Rule 38(1)(a)

Case details

Case number
3202217/2023
Decision date
28 May 2025
Hearing type
preliminary
Hearing days
2
Classification
contested

Respondent

Sector
transport
Represented
Yes
Rep type
barrister

Claimant representation

Represented
Yes
Rep type
barrister